NC0000299_Regional Office Historical File Pre 2018

,<3,4 S F
GE Betz, Inc. Material Safety Data Sheet
4636 Somerton Road
Trevose, PA 19053 Issue Date: 28-MAR-2005
Business telephone: [phone]
EMERGENCY TELEPHONE (Health/Accident): [phone]
1 PRODUCT IDENTIFICATION
PRODUCT NAME:
DIANODIC DN2478
PRODUCT APPLICATION AREA:
WATER -BASED CORROSION INHIBITOR.
2 COMPOSITION / INFORMATIONS ON INGREDIENTS
Information for specific product ingredients as required by the
U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer t0
additional sections of this MEER for our assessment of the potential
hazards of this formulation.
HAZARDOUS INGREDIENTS:
CASO CHEMICAL NAME
7778-53-2 PHOSPHORIC ACID, TRIPOTASSIUM SALT
Severe irritant (eyes)
1310-58-3 POTASSIUM HYDROXIDE (CAUSTIC POTASH)
Corrosive; toxic (by ingestion)
202420-04-0 CHLOROTOLYLTRIAZOLE SODIUM SALT
Potential irritant
No component is considered to be a carcinogen by the National Toxicology
Program, the International Agency for Research on Cancer, or the
Occupational Safety and Health Administration at OSHA thresholds for
carcinogens.
3 HAZARDS IDENTIFICATION
EMERGENCY OVERVIEW
WARNING
May cause slight irritation to the skin. Severe irritant to the
eyes. Mists/aerosols may cause irritation to upper respiratory

DOT hazard: Corrosive to aluminum, RQ
Emergency Response Guide #154
Odor: Mild; Appearance: Amber To Brown, Liquid
Fire fighters should wear positive pressure self-contained breathing
apparatus(full face -piece type). Proper fire -extinguishing media:
dry chemical, carbon dioxide, foam or water
POTENTIAL HEALTH EFFECTS
ACUTE SKIN EFFECTS:
Primary route of exposure; May cause slight irritation to the skin.
ACUTE EYE EFFECTS:
Severe irritant to the eyes.
ACUTE RESPIRATORY EFFECTS:
Mists/aerosols may cause irritation to upper respiratory tract.
INGESTION EFFECTS:
May cause gastrointestinal irritation with possible nausea,
vomiting, abdominal discomfort and diarrhea.
TARGET ORGANS:
No evidence of potential chronic effects.
MEDICAL CONDITIONS AGGRAVATED:
Not known.
SYMPTOMS OF EXPOSURE:
May c redness or itching of skin, irritation, and/or tearing of
eyes (direct contact).
SKIN CONTACT:
Remove contaminated clothing. Wash exposed area with a large
quantity of soap solution or water for 15minutes.
EYE CONTACT:
Immediately flush eyes with water for 15 minutes. Immediately
contact a physician for additional treatment.
INHALATION:
Remove victim from contaminated area to fresh air. Apply
appropriate first aid treatment as necessary.
INGESTION:
Do not feed anything by mouth to an unconscious or convulsive
victim. Do not induce vomiting. Immediately contact physician.
Dilute contents of stomach using 3-4 glasses milk or water.
NOTES TO PHYSICIANS:
No special instructions
5 FIRE FIGHTING MEASURES

FIRE FIGHTING INSTRUCTIONS:
Fire fighters should wear positive pressure self-contained breathing
apparatus (full face -piece type).
EXTINGUISHING MEDIA:.
'dry chemical, carbon dioxide, foam or water
HAZARDOUS DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
FLASH POINT:
> 20OF > 93C P-M(CC)
MISCELLANEOUS:
Corrosive to aluminum, RQ
UN3266;Emergency Response Guide k154
6 ACCIDENTAL RELEASE MEASURES
PROTECTION AND SPILL CONTAINMENT:
Ventilate area. Use specified protective equipment. Contain and
absorb on absorbent material. Place in waste disposal container.
Flush area with water. Wet area may be slippery. Spread sand/grit.
DISPOSAL INSTRUCTIONS:
Water contaminated with this product may be sent to a sanitary sewer
treatment facility,in accordance with any local agreement,a permitted
waste treatment facility or discharged under a permit. Product
as is - Incinerate or land dispose in an approved landfill.
7 HANDLING & STORAGE
HANDLING:
Alkaline. Do not mix with acidic material.
STORAGE:
Keep containers closed when not in use. Do not freeze. If frozen,
thaw and mix completely prior to use.
S EXPOSURE CONTROLS/PERSONAL PROTECTION
EXPOSURE LIMITS
CHEMICAL NAME
PHOSPHORIC ACID, TRIPOTASSIUM SALT
PEE (OSHA): NOT DETERMINED
TLV (ACGIH): NOT DETERMINED
POTASSIUM HYDROXIDE (CAUSTIC POTASH)
PEE (OSHA): 2 MG/M3(CEILING)
TLV (ACGIH): 2 MG/M3(CEILING)
CHLOROTOLYLTRIAZOLE SODIUM SALT
PEE (OSHA): NOT DETERMINED
TLV (ACGIH): NOT DETERMINED
ENGINEERING CONTROLS:
Adequate ventilation to maintain air contaminants below exposure
limits.
PERSONAL PROTECTIVE EQUIPMENT:
Use protective equipment in accordance with 29CFR 1910 Subpart I
RESPIRATORY PROTECTION:
A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSMA'S 29 CFR
1910.134 AND ANSI ZS8.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER
WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.
USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED

WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR -RESPIRATORS.
I£ air -purifying respirator use is appropriate, use a
respirator With dust/mist filters.
SKIN PROTECTION:
neoprene gloves-- Wash cff after each use. Replace a,
necessary.
EYE PROTECTION:
splash proof chemical goggles
9 PHYSICAL & CHEMICAL PROPERTIES
Specific Gray.(70F,21C) 1.392 Vapor Pressure (mmHG) - 18.0
Freeze Point (F) -- 11 Vapor Density (air-1) < 1.00
Freeze Point (C) - -12
Viscosity(cps 90F,21C) 18 i Solubility (water) 100.0
Odor Mild
Appearance Amber To Brown
Physical State Liquid
Flash Point P-M(CC) > 20OF > 93C
PH As Is (approx.) 14.4
Evaporation Rate (Ether-1) < 1.00
NA = net applicable ND = not determined
10 STABILITY & REACTIVITY
STABILITY:
Stable under normal storage conditions.
HAZARDOUS POLYMERIZATION:
Will not occur.
INCOMPATIBILITIES:
May react with strong oxidizers.
DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
INTERNAL PUMPOUT/CLEANOUT CATEGORIES:
"Bn
11 TOXICOLOGICAL INFORMATION
Oral LD50 RAT: - >2,000 mg/kg
NOTE - Estimated value
Dermal LD50 RABEIT: >2,000 mg/kg
NOTE - Estimated value
12 ECOLOGICAL INFORMATION

AQUATIC TOXICOLOGY
Daphnia magna 48 Hour Acute Toxicity (Estimated)
LC50= 910; No Effect Level- 520 mg/L
Fathead Minnow 96 Hour Acute Toxicity (Estimated)
LC50= 360; No Effect Level= 140 mg/L
BIODEGRADATION
EOD-28 (mg/g): 21
HOD-5 (mg/g): 12
COD (mg/g); 160
TOC (mg/g): 60
13 DISPOSAL CONSIDERATIONS
If this undiluted product is discarded as a waste, the US RHEA
hazardous waste identification number is
D002=Ccrrosive(pH).
Please be advised; however, that state and local requirements for
waste disposal may be more restrictive or otherwise different from
federal regulations. Consult state and local regulations regarding
the proper disposal of this material.
14 TRANSPORT INFORMATION
DOT HAZARD: Corrosive to aluminum, RQ
❑N / NA NUMBER: W3266
DOT EMERGENCY RESPONSE GUIDE #: 154
15 REGULATORY INFORMATION
TSCA:
All components of this product are listed in the TSCA inventory.
CERCLA AND/OR SARA REPORTABLE QUANTITY (RQ):
1,232 gallons due to POTASSIUM HYDROXIDE (CAUSTIC POTASH):
SARA SECTION 312 HAZARD CLASS:
Immediate(acute)
SARA SECTION 302 CHEMICALS:
No regulated constituent present at OSHA thresholds
SARA SECTION 313 CHEMICALS:
No regulated constituent present at OSHA thresholds
CALIFORNIA REGULATORY INFORMATION
CALIFORNIA SAFE DRINKING WATER AND TOXIC
ENFORCEMENT ACT (PROPOSITION 65) CHEMICALS PRESENT:
No regulated constituents present
MICHIGAN REGULATORY INFORMATION
No regulated constituent present at OSHA thresholds
16 OTHER INFORMATION
NFPA/HMIS
Health
2
Fire
I
Reactivity
0
Special
ALX
CODE TRANSLATION
Moderate Hazard
Slight Hazard
Minimal Hazard
PH above 12.0

(1) Protective Equipment B Goggles,Gloves
(1) refer to section E of MSDS for additional protective equipment
recommendations.
CHANGE LOG
EFFECTIVE
DATE REVISIONS TO SECTION: SUPERSEDES
--------- --------------------- ----------
MSDS status: 21-JAN-1999 * NEW —
16-MAR-1999 12 21-JM-1999
28-MAR-2005 2 16-MAR-1999

GE Bed
GE Betz, Inc. Material Safety Data Sheet
4636 Somerton Road
Trevose, PA 19053 Issue Date: 03-7UL-2002
Business telephone: [phone]
EMERGENCY TELEPHONE (Health/Accident): [phone]
1 PRODUCT IDENTIFICATION
PRODUCT NAME:
CORRSHIELD MD401
PRODUCT APPLICATION AREA:
WATER -BASED CORROSION INHIBITOR/DEPOSIT CONTROL AGENT.
2 COMPOSITION / INFORMATION ON INGREDIENTS
Information Ear specific product ingredients as required by the
U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to
additional sections of this MSDS for our assessment of the potential
hazards of this formulation.
HAZARDOUS INGREDIENTS
CAS/{
CHEMICAL NAME
7631-9s-0
SO➢IUM MOLYSDATE (MOLYBDIC ACID,DISODIUM SALT)
Potential irritant (respiratory); potential lung
toxicity
1310-73-2
SODIUM HYDROXIDE (CAUSTIC SODA)
Corrosive; toxic (by ingestion)
29385-43-1
1-H-BENZOTRIAZOLE,METHYL- (TOLYLTRIAZOLE; TTA)
Solid is an irritant (by all routes); liquid is
corrosive
No component
is considered to be a Carcinogen by the National Toxicology
Program, the
International Agency for Research on Cancer, or the
Occupational
Safety and Health Administration at OSHA thresholds for
carcinogens.
3 HAZARDS IDENTIFICATION
EMERGENCY OVERVIEW
CAUTION

May cause slight irritation to the skin. May cause moderate
irritation to the eyes. Mists/aerosols may cause irritation to
upper respiratory tract.
DOT hazard is not applicable
Emergency Response Guide is not applicable
Odor: Slight; Appearance: Yellow, Liquid
Fire fighters should wear positive pressure self-contained breathing
apparatus(full face -piece type). Proper fire -extinguishing media:
.....rrr•ryr chemical carbon dioxide,
dorm orwater
rrrrrrrrrrrrrrrrr+.+ .*
r rr r rr r r rr rrrrrr
POTENTIAL HEALTH EFFECTS
ACUTE SKIN EFFECTS:
Primary route of exposure; May cause slight irritation to the skin.
ACUTE EYE EFFECTS:
May cause moderate irritation to the eyes.
ACUTE RESPIRATORY EFFECTS:
Mists/aerosols may cause irritation to upper respiratory tract.
INGESTION EFFECTS:
May cause slight gastrointestinal irritation.
TARGET ORGANS:
Prolonged or repeated exposures may cause toxicity to the lung.
MEDICAL CONDITIONS AGGRAVATED:
Not known.
SYMPTOMS OF EXPOSURE:
May cause redness or itching of skin.
4 FIRST AID MEASURES
SKIN CONTACT:
Wash thoroughly with soap and water. Remove contaminated clothing.
Get medical attention if irritation develops or persists.
EYE CONTACT:
Remove contact lenses. Hold eyelids apart. Immediately flush eyes
with plenty of low-pressure water for at least 15 minutes. Get
immediate medical attention.
INHALATION:
If nasal, throat or lung irritation develops - remove to fresh air
and get medical attention.
INGESTION:
Do not feed anything by mouth to an unconscious or convulsive
victim. Do not induce vomiting. Immediately contact physician.
Dilute contents of stomach using 3-4 glasses milk or water.
NOTES TO PHYSICIANS:
No special instructions
5 FIRE FIGHTING MEASURES

FIRE FIGHTING INSTRUCTIONS:
Fire fighters should wear positive pressure self-contained breathing
apparatus (full face -piece type).
EXTINGUISHING MEDIA:
dry chemical, carbon dioxide, foam or water
HAZARDOUS DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
FLASH POINT:
a 20OF o 93C P-M(CC)
6 ACCIDENTAL RELEASE MEASURES
PROTECTION AND SPILL CONTAINMENT:
Ventilate area. Use specified protective equipment. Contain and
absorb on absorbent material. Place in waste disposal container.
Flush area with water. Wet area may be slippery. Spread sand/grit.
DISPOSAL INSTRUCTIONS:
Water contaminated with this product may be sent to a sanitary sewer
treatment facility,in accordance with any local agreement,a permitted
waste treatment facility or discharged under a permit. Product
as is - Incinerate or land dispose in an approved landfill.
7 HANDLING & STORAGE
HANDLING:
Alkaline. Do not mix with acidic material.
STORAGE:
Keep containers closed when not in use. Do not freeze. If frozen,
thaw and mix completely prior to use.
S EXPOSURE CONTROLS/PERSONAL PROTECTION
EXPOSURE LIMITS
CHEMICAL NAME
SODIUM MOLYEDATE (MOLYBDIC ACID,D25011UM SALT)
PEE (OSHA): 5 MG/M3(AS Me)
TLV MOUTH); 0.5 MG/M3(AS Me) RESPIRABLE FRACTION
SODIUM HYDROXIDE (CAUSTIC SODA)
PEL (OSHA): 2 MG/M3
TLV (ACGIH): 2 MG/M3(CEILING)
1-H-BENZOTRIAZOLE,METHYL- (TOLYLTRIAZOLE; TTA)
PEL (OSHA): NOT DETERMINED
TLV (ACGIH): NOT DETERMINED
ENGINEERING CONTROLS:
Adequate ventilation to maintain air contaminants below exposure
limits.
PERSONAL PROTECTIVE EQUIPMENT:
Use protective equipment in accordance with 29CFR 1910 Subpart I
RESPIRATORY PROTECTION:
A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 TER
1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER
WORKPLACE CONDITIONS WARRANT A RESPIRATOR'S USE.
USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED
WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR -RESPIRATORS.
If air -purifying respirator use is appropriate, use a
respirator with dust/mist filters.

SKIN PROTECTION:
neoprene gloves-- Wash off after each use. Replace as
.of ea6a ry.
EYE PROTECTION:
splash proof chemical goggles
9 PHYSICAL & CHEMICAL PROPERTIES
Specific Gray.(70F,21C) 1,290 Vapor Pressure (mmHG) - 18.0
Freeze Point (F) 18 Vapor Density (air=1) c 1.00
Freeze Point (C) -8
viscosity(cps 90F,21C) 12 & Solubility (water) 100.0
Odor Slight
Appearance Yellow
Physical State Liquid
Flash Point P-M(CC) > 20OF > 93C
PH As Is (approx.) 13.4
Evaporation Rate (Ether=1) c 1.00
NA = not applicable ED = not determined
10 STABILITY & REACTIVITY
STABILITY:
Stable under normal storage conditions.
HAZARDOUS POLYMERIZATION:
Will not occur.
INCOMPATIBILITIES:
May react with strong oxidizers.
DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
INTERNAL PUMPOUT/CLEANOUT CATEGORIES:
nBn
11 TOXICOLOGICAL INFORMATION
Oral LD50 RAT: >4,000 mg/kg
NOTE - Estimated value
Dermal LD50 RABBIT: >2,000 mg/kg
NOTE - Estimated value
12 ECOLOGICAL INFORMATION
AQUATIC TOXICOLOGY
Daphnia magna 48 Hour Static Acute Bioassay (pH adjusted)
0% Mortality= 5000 mg/L
Fathead Minnow 96 Hour Static Acute Bioassay (pH adjusted)
LC50= 3320; No Effect Level= 2110 mg/L
Menidia beryllina (Silversides) 96 Hour Static Acute Bioassay
(pH adjusted)
LC50= 4410; No Effect Level= 1562 mg/L
Mysid Shrimp 48 Hour Static Acute Bioassay (PH adjusted)
LC50= 6810; No Effect Level= 1562 mg/L
Rainbow Trout 96 Hour Static Renewal Bioassay (pH adjusted)
LC50= 1910; No Effect Level- 625 mg/L
BIO➢EGRADATION

ROD-28 (mg/g): 2
BOD-5 (mg/g): 0
COD (mg/g): 31
TOO (mg/g): 11
13 DISPOSAL CONSIDERATIONS
If this undiluted product is discarded as a waste, the US ROM
hazardous waste identification number is
D002=Corrosive(pH).
Please be advised; however, that state and local requirements for
waste disposal may be more restrictive or otherwise different from
federal regulations. Consult state and local regulations regarding
the proper disposal of this material.
14 TRANSPORT
DOT HAZARD: Not Applicable
UN / NA NUMBER: Not applicable
DOT EMERGENCY RESPONSE GUIDE H: Not applicable
15 REGULATORY INFORMATION
TSCA:
All components of this product are listed in the TSCA inventory.
CERCLA AND/OR SAM REPORTABLE QUANTITY (SO):
0,759 gallons due to SODIUM HYDROXI➢E (CAUSTIC FOUR);
USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS:
SEC.G5, G9
SAM SECTION 312 HAZARD CLASS:
Immediate(acute);Delayed(Chronic)
SAM SECTION 302 CHEMICALS:
No regulated constituent present at OSHA thresholds
SAM SECTION 313 CHEMICALS:
No regulated constituent present at OSHA thresholds
CALIFORNIA REGULATORY INFORMATION
CALIFORNIA SAFE DRINKING WATER AND TOXIC
ENFORCEMENT ACT (PROPOSITION 65) CHEMICALS PRESENT:
No regulated constituent present at OSHA thresholds
MICHIGAN REGULATORY INFORMATION
No regulated constituent present at OSHA thresholds
16 OTHER INFORMATION
NFPA/HMIS
Health
1
Fire
0
Reactivity
0
Special
ALK
(1) Protective Equipment
B
CODE TRANSLATION
Slight Hazard
Minimal Hazard
Minimal Hazard
PH above 12.0
Goggles,Gloves
(1) refer to section 8 of MODS for additional protective equipment
recommendations.

CHANGE LOG
EFFECTIVE
DATE
REDS status: 13-FEB-1997
15-MAY-1999
21-JUL-1990
13-JM-2000
02-JUN-2000
16-JAN-2002
03-JUL-2002
REVISIONS TO SECTION: SUPERSEDES
** NEW **
15 13-FEB-1999
15 15-MAY-1999
12 21-JUL-1999
12 13-JM-2000
3,4,16 02-SUN-2000
12 16-JM-2002

GE Betz, Inc. Material Safety Data Sheet
4636 Somerton Road
Trevose, PA 19053 Issue Date: 07-DEC-2004
Business telephone: [phone]
EMERGENCY TELEPHONE (Health/Accident): [phone]
1 PRODUCT IDENTIFICATION
PRODUCTNAME:
SPECTRUS NX108
PRODUCT APPLICATION AREA:
BIOCIDE
2 COMPOSITION / INFORMATION ON INGREDIENTS
Information for specific product ingredients as required by the
U.S. OSHA HAZARD COMMUNICATION STANDARD is listed. Refer to
additional sections of this MSDS for our assessment of the potential
hazards of this formulation.
HAZARDOUS INGREDIENTS:
CAB# CHEMICAL NAME
3252-43-5 DIBROMOACETONITRILE
Irritant (skim ; IARC=3 (carcinogen status not
classifiable)
10222-01-2 DBNPA(2,2-DIBROMO-3-NITRILOPROPIONAMIDE)
Corrosive (eyes); highly tesic(by inhalation);
toxic(by ingestion); potential sensitizer
7647-15.-6 SO➢IUM BROMIDE
Irritant
1113-55-9 MONOBROMO-3-NITRILOPROPIONAMIDE
Irritant
73003-80-2 2,2-DIBROMOPROPANEDIAMIDE
Potential irritant
No component is considered to be a carcinogen by the National Toxicology
Program, the International Agency for Research on Cancer, or the
Occupational Safety and Health Administration at OSHA thresholds for
carcinogens.
3 HAZARDS IDENTIFICATION

EMERGENCY OVERVIEW
DANGER
May cause moderate irritation to the skin. Potential skin
sensitizer. Corrosive to the eyes. Mists/aerosols cause irritation
to the upper respiratory tract.
DOT hazard: Corrosive to aluminum
Emergency Response Guide #153
Odor: Slight; Appearance: Yellow To Amber, Liquid
Fire fighters should wear positive pressure self-contained breathing
apparatus(full face -piece type). Proper fire -extinguishing media:
Flood with water. Use of Coe or foam may not be effective.
•.r*wr.wr,.♦♦.•r,....x...+..+a..•x..:..xxwr:r*w*•wwwww♦.v.w.r.r.r:.x..+a.a...x.cxrr:.
POTENTIAL HEALTH EFFECTS
ACUTE SKIN EFFECTS:
Primary route of exposure; May cause moderate irritation to the
skin. Potential skin sensitizer.
ACUTE EYE EFFECTS:
Corrosive to the eyes.
ACUTE RESPIRATORY EFFECTS:
Mists/aerosols cause irritation to the upper respiratory tract.
INGESTION EFFECTS:
May cause gastrointestinal irritation, very large doses may cause
diarrhea, depression, colic and death. May also cause severe
allergic reactions in sensitive individuals.
TARGET ORGANS:
Repeated skin contact may cause sensitization.
MEDICAL CONDITIONS AGGRAVATED:
Not known.
SYMPTOMS OF EXPOSURE:
Causes redness or itching of skin, possibly leading to burns
(dependent on the length of exposure).
4 FIRST AID MEASURES
SKIN CONTACT:
Wash thoroughly with soap and water. Remove contaminated clothing.
Thoroughly wash clothing before reuse, Get medical attention if
irritation develops or persists.
EYE CONTACT:
URGENT! Immediately flush eyes with plenty of low-pressure water
for at least 20 minutes while removing contact lenses. Hold eyelids
apart. Get immediate medical attention.
INHALATION:
Remove to fresh air. if breathing is difficult, give oxygen. If
breathing has stopped, give artificial respiration. Get immediate
medical attention.
INGESTION:

Do not feed anything by mouth to an unconscious or convulsive
victim. Do not induce vomiting. Immediately contact physician.
Dilute contents of stomach using 3-9 glasses milk or water.
NOTES TO PHYSICIANS:
No special instructions
5 FIRE FIGHTING MEASURES
FIRE FIGHTING INSTRUCTIONS:
Fire fighters should wear positive pressure self-contained breathing
apparatus (full face -piece type).
EXTINGUISHING MEDIA:
Flood with water. Use of CO2 or foam may not be effective.
HAZARDOUS DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
FLASH POINT:
> 20OF > 93C SETA(CC)
MISCELLANEOUS:
Corrosive to aluminum
UN3265;Emergency Response Guide k153
6 ACCIDENTAL RELEASE MEASURES
PROTECTION AND SPILL CONTAINMENT:
Ventilate area. Use specified protective equipment. Contain and
absorb on absorbent material. Place in waste disposal container.
Flush area with water. Spread sand/grit. Neutralize with soda ash.
DISPOSAL INSTRUCTIONS:
Water contaminated with this product may be sent to a sanitary sewer
treatment facility,in accordance with any local agreement,a permitted
waste treatment facility or discharged under a permit. Product
as is - Dispose of in approved pesticide facility or according to
label instructions.
7 HANDLING & STORAGE
HANDLING:
Acidic. Corrosive(Eyes). Do not mix with alkaline material.
STORAGE:
Keep containers closed when not in use. Avoid excessive heat and
contamination. Stare only in vented containers.
8 EXPOSURE CONTROLS/PERSONAL PROTECTION
EXPOSURE LIMITS
CHEMICAL NAME
FED (OSHA): NOT DETERMINED
TLV (ACGIN): NOT DETERMINED
DENPA(2,2-➢IBROMO-3-NITRILOPROPIONAMIDE)
PEL (OSHA): NOT DETERMINED
TLV (ACGIH): NOT DETERMINED
MISC. Note- m nufacturer's recommended exposure limit: 2
mg/m3 (ceiling) -for powder.
SODIUM BROMIDE
PEL (OSHA): NOT DETERMINED

TLV (ACGIH): NOT DETERMINED
MONOEROMO-3-NITRILOPROPIONAMIDE
PEL (OSHA): NOT DETERMINED
TLV (ACGIH): NOT DETERMINED
PEL (OSHA): NOT DETERMINED
TLV (ACGIH): NOT DETERMINED
6) EXPOSURE CONTROLS/PERSONAL PROTECTION (continued)
ENGINEERING CONTROLS:
Adequate ventilation to maintain air contaminants below exposure
limits.
PERSONAL PROTECTIVE EQUIPMENT:
Use protective equipment in accordance with 29CPR 1910 Subpart I
RESPIRATORY PROTECTION:
A RESPIRATORY PROTECTION PROGRAM THAT MEETS OSHA'S 29 CPR
1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER
WORKPLACE CON➢ITIONS WARRANT A RESPIRATOR'S USE.
USE AIR PURIFYING RESPIRATORS WITHIN USE LIMITATIONS ASSOCIATED
WITH THE EQUIPMENT OR ELSE USE SUPPLIED AIR -RESPIRATORS.
If air -purifying respirator use is appropriate, use a
respirator with organic vapor/acid gas cartridges and
dust/mist prefilter,
SKIN PROTECTION:
butyl gloves-- Wash off after each use. Replace as necessary.
EYE PROTECTION:
splash proof chemical goggles
9 PHYSICAL & CHEMICAL PROPERTIES
Specific Gray.(90F,21C) 1.269
Freeze Point (F) - - 0
Freeze Point (C) - -18
Viscosity(cps 70F,21C) 69
Odor
Appearance
Physical State
Flash Paint SETA(CC)
PH As Is (approx.)
Evaporation Rate (Ether=l)
Vapor Pressure (.HG) < 0.1
Vapor Density (air=1) > 1.00
% Solubility (water) 100.0
Slight
Yellow To Amber
Liquid
>.20OF > 93C
1.9
< 1.00
NA . not applicable ND = net determined
10 STABILITY & REACTIVITY

STABILITY:
Stable under normal storage conditions.
HAZARDOUS POLYMERIZATION:
Will not occur.
INCOMPATIBILITIES:
Above 120 deg. C bromine, cyanogen bromide and dibromoacetonitrile
are formed. May react with bases or strong oxidizers.
DECOMPOSITION PRODUCTS:
Thermal decomposition (destructive fires) yields elemental oxides.
INTERNAL PUNPOUT/CLEANOUT CATEGORIES:
nBn
11 TOXICOLOGICAL INFORMATION
Oral LD50 RAT: 510 mg/kg
Dermal LD50 RABBIT: >2,000 mg/kg
Inhalation LC50 RAT: 1.325 mg/L/4hr
NOTE - Rat inhalation LC50: >200 ppm/6hr
Skin Irritation Score RABBIT: NOT CORR
NOTE - Not DOT corrosive
Skin Sensitization G.PIG: POSITIVE
NOTE - 9/10 Positive from 5% aqueous DBNPA (active)
Skin Sensitization HUMAN: NEGATIVE
NOTE - 0/26 Positive from 1,250 ppm aqueous DBNPA (active)
Ames Assay NEGATIVE
Non -Ames Mutagenicity NEGATIVE
NOTE - CHO/HGPRT;Micronucleus Test;Rat Hepatocyte Unscheduled DNA
12 ECOLOGICAL INFORMATION
AQUATIC TOXICOLOGY
Bluegill Sunfish 96 Hour Static Acute Bioassay
LC50= 6.5 mg/L
Daphnia magna 21 Day Flow-Thru Life -Cycle Chronic Bioassay
Reproduction EC50- .65; Reproduction NOEL- .35 mg/L
Daphnia magna 98 Hour Static Renewal Bioassay
LC50= 3.3; No Effect Level= 2.15 mg/L
Fathead Minnow 96 Hour Static Renewal Bioassay
LC50= 8.9; No Effect Level= 3.1 mg/L
Marine Copepod (Acartia tonsa) 98 Hour Static Acute Bioassay
LC50= 1.98 mg/L
Rainbow Trout 96 Hour Static Acute Bioassay
LC50= 2.3; No Effect Level= 1.8 mg/L
Sheepshead Minnow 96 Hour Static Acute Bioassay
LC50= ] mg/L
BIODEGRADATION
BOD-28 (mg/g): 0
BOD-5 (mg/g): 0
COD (mg/g): 1090
TOO (mg/g): 300
13 DISPOSAL CONSIDERATIONS

If this undiluted product is discarded as a waste, the US RCRA
hazardous waste identification number is
D002=Corrosive(pH).
Please be advised; however, that state and local requirements for
waste disposal may be more restrictive or otherwise different from
federal regulations. Consult state and local regulations regarding
the proper disposal of this material.
14 TRANSPORT INFORMATION
DOT HAZARD: Corrosive to aluminum
ON / NA NUMBER: UN3265
DOT EMERGENCY RESPONSE GUIDE W: 153
15 REGULATORY INFORMATION
TSCA:
This is an EPA registered biocide and is exempt from TSCA
inventory requirements.
CERCLA AND/OR SABA REPORTABLE QUANTITY (RQ):
No regulated constituent present at OSHA thresholds
FIFRA REGISTRATION NUMBER:
3896- 95
FOOD AND DRUG ADMINISTRATION:
The ingredients in this product are approved by FDA under 21 CFR
116.300.
USDA FEDERALLY INSPECTED MEAT AND POULTRY PLANTS:
SEC.GS,G]
SABA SECTION 312 HAZARD CLASS:
Immediate(acute);Delayed(Chronic)
SABA SECTION 302 CHEMICALS:
No regulated constituent present at OSHA thresholds
SARA SECTION 313 CHEMICALS:
NO regulated constituent present at OSHA thresholds
CALIFORNIA REGULATORY INFORMATION
CALIFORNIA SAFE DRINKING WATER AND TOXIC
ENFORCEMENT ACT (PROPOSITION 65) CHEMICALS PRESENT:
No regulated constituents present
MICHIGAN REGULATORY INFORMATION
No regulated constituent present at OSHA thresholds
16 OTHER INFORMATION
NFPA/HMIS
Health
Fire
Reactivity
0
Special
ACID
(1) Protective Equipment
B
CODE TRANSLATION
Serious Hazard
Slight Hazard
Minimal Hazard
AS below 2.1
Goggles,Gloves
(1) refer to section 8 of MSDS for additional protective equipment
recommendations.
CHANGE LOG

EFFECTIVE
DATE
---------
REVISIONS TO SECTION:
SUPERCEDES
NEES status: 15-SEP-1999
---------------------
17-SEP-1999
12
15-SEP-1999
02-DEC-1997
15
17-SEP-1997
23-DEC-1999
15
02-DEC-1999
21-APR-1998
;EDIT:9
23-DEC-1995
01-JUL-1998
2
21-APR-1998
08-JUL-1998
2,3,5,9,8,14;EDIT:S
01-JUL-1998
27-JUL-1998
9
09-JUL-1998
28-MAY-1999
3,5,14
27- UL-1998
26-APR-2000
2
28-MAY-1999
29-NOV-2000
4
26-APR-2000
09-AUG-2001
15
29-NOV-2000
28-SON-2002
15
09-AUG-2001
09-DEC-2004
3,5,14
2B-SUN-2002

Jan.10'2006 09:9:37 028-669-6969 �� I�-'iSa�F� b6770 P.901
FAX
JAN Q BASF Corpo ation
I I ' � 2005
' �I 1451 andHliNAad
�nka NC 2 723
Daft d
Number of pages Including rover sheet
Phone
Fax Phone
CC:
rl

JAN.1012006 09:30 028-667-6969 BASF
d
VIOCTD5WEMfCALTREATW ENT
-�.....•tNORKSHEEffi-ORM
ThefollowMgcalcuMmaar9'to/ PertonnedonarrybloddalpmduebuN eydi.
Ca"irm. Thleworksheetm'us�tre oompte'a3d aepara191yfar eadt BfoeiOaf ocl Nr
anfifh�lapprapr7atea��arte29det'o'R�ede6i�rated.�iea6wltlat8lanla,Uorrs eiarma
t
U,
Facility Name !�Ze a
NPDES#NC.G !�OOGO /
Com* 2.1i,JcaorSE
HecettiAng sEeam_L�fimidtar
(MFabove Fnbm UcnsupplledtyVeDMalmof.Waba ut liM
What Is the Avelage D011yDiaeharge (AIUD,) valame of to,,
�.tea9e catcalalesrednsbeam wastet;rmc>3rlbanar:(A�ao yea
/l .y�A—pax lag ( ) X
= (7610)(o.546)+(A.o.D) - ( x0.646)
M* Value q,U1dC�aepr�en�ibe'wastecaacerahaliCh 9nihereod
-What k the pane of the Whale Product chgakel beabnmt props
Tu.dnRv S9�.a:nNaE'
WMAfmtl ar.tlesrtge rate .(A R.) knead hr3hfe•opp➢wfim,?
z1FWhde'prdud aeeU in6a4brPeabd. - .
9MM924hr*od
'Please saate,ylaFtl ounce§ Se mdlame)aaas["be r�vertec
''C�remsafgrrodoct='fluidve:o'Fgrtadtid'X 9 ,mefer X
taBU, oz
f6770 P.002
e e0660

JAN. 10.2006 09:38 628-667-6969 BASF I $6770 P.003
Fadfrly3dame: %�i' fdPbtS#�1GC
E;sffmatO totalwlums of the water Irarldtingsystem bfseer emry
On sn sttachetl shee! pieass pmvldefudttk;agprt for We eetims&�
SAdhgfagoon Oka, sto) /nluys'
'Worm— , 05- - milibngallons �r %Gf/Gt2
What It me pH of the twndlfng system prior io=6lodde ad"W? if
Whatdathe deCay.aafe (O_Ki of iheproGr�d7 FunlmWm, r
ds9rada9onmostbe sfakdatpH desetaxl&fln Ai2.ryd3reFsntlsW
the is dre #Ms required forlhe Mial productto degradeto hah
aopfes aftflawaees efilgsdata. —W `
Sit. _� ,_ 3taays
TWdesayratpisdquaffa H:L X g.69 =
(iaiculateAiegradagon fadpr:{i7:�.). 'iris isit
(Volume)
[mte) + (b.lc) _ ° +.( )
r)
Qalnl><e��teady'$fa(e)d)6diapge L^�ra�7ffid69rs'
fJischg'Cone. c001
Eatcufais tancenfrafion ofbiorldeipsir"m dudngfew ftw cond"a
(Reoelv#4 ream Conaentnidon):
.fOisrh9. imnci x x f!9-a+tT
itl0 IOU =
IV ealculaie WouiatedllmWon.
tlst all LCW and EC60 data e
stwolditiq algh). 7Aessepi

JAN.10'2006 09:38 828--�6__67/-6969 GASP 26770 P.009
. .,Facifity9Vame: /77`�Y' 'AiPDES# N
Choose the loweal LME-050 fisted nbw /d G S o 07
Enwthe LC50/EM: �6U
IfIV143MO j54.t.)is 3ees�Ihan�i'days. yeAbon the fallowing.cal laflon.
fZa0W ted Umffi*en = 9:05 x L,= = a
tfthehalfille (14,6_)L%gmaEerMmvoequ8
Regulatedtknita0on = 0.01 x LC50 =
3, 6 mgdilet
r�aitae�rmte�ecelrm9sucamcnnba�afler,:
o--gffs2 mwwbr
2u, RNalyals.
,tithe receMn0sheam maceahatl0lf to gf0aterihafltlreeWeulWed
unecoapl9b�'fMu5a
&reraonan ifesptmWble Ohaxge
//Name(PHrd)
A�`erion-lroulhlaFnrg'idde ilVuA4heet{#WftersmTmmaheve)
Name (Print)
6"ig0ature
A6'!te MANw yn, m4sf0? of Kulol �d8lttf/
Agr+ilScTgxko/kqgtJAt
15Zi MSR Sandt9 Cen6xr
Attu: Todd QrWanwn
zw'.Q.F"101(6 Mo0 , 13

,SAn.10'2006 09:39
028-667-6969
BASF
t6790
P.005
IcaDpe . zfnA or chtomIm are prai Imihe Propitaedbladdal Cnmpou
be lead for each metal andrormetaf compound present in the bloclde. Lb
WLvjAinalaavelgM M. , and the comm�bafiennN dreaMAsl compalm
dkuavery metal prassi lhe•bbdit
Adel'dlChAlife=tFur fs M I 0a Famnfi_• W
EXAMPLE _
CWW ',t, w..i B31.5m laaafa .-,NN0gh
Onaage Bate or I rocidw(DR) lrrom page 41:. .
DR = a2rnslday ..
Jaremga'LJafty�fscRaHs''i�SD)7(rred7'VaW 7� L //I
ADD- _ - miWor,90oWday
Discharge Cmmeobadorr (DCI or Bloemet
DC
n i _ d d2 WelilaVY
_ AM{ mifllongagorrs7dayj t mime
ComrertbCtomlmograrnsllttar(ppb); .
iob,(pg/q = �c �ramsbrhiRan gaq x.. x t=
$.4g5x9gB7fMrsMii4lon pal .
CaleutaEudre frae6on cEmeiarin'tha metalcomalnbigromgwund e -
10 Ow
CaramatetharraL$en or marat Pe grebiocidal r popnd.jBE)t ...
OF � MF x MCC _ x,
Me)
'F'+akJlfaleiRBCorlaetltrBVen of metariniltatllaclYaega (M)c
M e DD x BF = .mrt x
CakdletaHbeErtMmammefal coacedlratian�IblC).at9vqifow.condW
IMC = M x l 160% ugQ x % _
Ads
xtegwatedNemYag000rme�l (hamgmiosQ: .mvl
Cappv-7W'"lerqualRyadianleael' Zme-E%pp'6wa64rqua�Igradioh lever

JM.1012006 09:39 828-667-5969 BASF f6770 P.006
Thet'o
Carolh
=111Qi
i
11.
1
9
I
/ 81OCIDEYCHEAhjMTFMhjv
ENT
�"R"HEET-FORM-101
lowing catculagnns or, to� epeda=ad w any bloddal products idffn
atelydi
at
the
a This morksheet indsi ,a compteted seperafely for each bfoddabIn
Dcluo"n
Thus
9FInelatete4af entewdhRethe de9I9natpdOvmw" 49 WaHoFu I
erfamad
tall
Facility Name ...C.a . -a
NPDES#HC_6-_57eObO
O
Cvhnriy... �l�JCoiN,FaE'
#iadaiung stream. • `�� C-,9L,.
'74
(AM above laid mabcn suppliAd me Dlvwon of Water Ouallly)
What 6 the Average Mlly Dlscbarge(&D.D,)wMme at the water h
rdling sy
to
Heaserakulalegiielasheam tA+'e5[e'Cromm�traLon+QVJC.in'perdant9
- fired
qh s
� - -
�Qta)Ga.s4s)+fA.o•�3 (z3Ho.548) + G
,�
Fhte vatlre(I .,apresanLviltay(ade ,o-aEon trm,9,axenaw[rtg
-dreamdminplov,
lowenryll
Mat is dta name atft whute product chemkal ho tment proposed
bruse in i
he dled
agafdn
SAlYJO9
zteas6IW*&adhas4n98dImfta;d paccant mqmtait&er
-3TIT
o 7r
�b.$�d'ear-3—j�JllR/LtSj�,@�Yvj�>/Wdtiiois7xaw
I
'feed✓ga�iata`7w�.�d- 5i
-fig
llca8an7'fheamtls
Sore/
tgsn
d'vAwleprodud Baud to a W rPend.
gratfs24r pedal. (. :'"c✓
"
,
a
7esae weee,'9afdouncesf8 w7ame)srmstbe ccetver�dto:9rams (a'
). Tb3f*mBliforlirlad
=rams of'pradact='fluidasz.Ofprsdud'3( 7 nai.vwalar X
2C
erp
12DA ca. 1 gal.

JAN.10'2006 09:40 828-667-6969 BASE
Facil4yitam¢:_,._� t4ht]F-S#
Hsdenate tareivolutne Of the Water handling system between entry
On an attached sheet Please provide justireaticnkrthis estimab
'hPidlrr0lagoon alas, etc) 1A)"MA,
nfoimr� J, Dt�S mllPantrallons
~is the PH of the handlirg�systom prior to blodide addition? if
iNhatis•ihe derayrate (p.9C)oipre,3nud�AJ tfamiamwn, assume
degrada3cn aa;�4+e s�tedafpHSevMaahnin AP2pW-ahmlaai eatB
ills Ps thelmle roquired'krrthe inttla}produGtn de�ade/o halPOFB
coPfes pfYhe.sourees WlMedafa. �l�L%�
Ii.L=. d.2J ^d7sys -
'Rre decay rate PxdquaVkf FtJ. X 0,6s.
gil9� tiegladaseA faCFerOw .}. -MIS tS ih83R$P OIIYaf P053'etlCn
_ •.6.F. = N IOume) +
_'CalcNhfe6teaayState197s<.fiarge Win; '
f/�ttF�lCma
sslaulale carlwntiadon oPbfodldelnepeafrf duiing:tow flow snntlNier
. - (ftecePukrg Stream Cdneaneatl8n} ',
.fig Pex.8 R:tt &%l
CPh7 = 9'06
tlf. t:alaulafe ragul2@dlimftaelvn,. '
List ail LC56 an9 EC5D data avallablefcirthe sdwla prcduet acconun 3o gre
s7+ooid6afa npll}j. �4emaP�#�'�Pteami�resourresPFBire
' Qrcr3sisln
..P�s1,FENL�1pJfy�
Teat�,ra'hbn
.. �jS
iar�m rl�nt✓a�
6�.
ioi9, Ca�R»
r
.2Yi.�(+1✓7
46�9L
s�as✓,�r.>a mml�
qc,.f�
A.W.Q.:Pam 101 (b@Qdaj
7
d G190 P.007
th-.

BAH.10'2006 09:40 B28-6667-69969 BASF
• FaCIT�y�Nalila: ✓T{�T
choose fhe lowest L0601EC60 tlated s'dlova:
Enmrthe l-rOSC00: 0.45
if 0w hagfite {{'f.L) c Jess�IBas.d Bays, pert
•'RegsleledLftliaHon --0Om x L-M =
UCiehalfife (IiL)isgMWrtefl."egoatl
Regula@d Umbnon = 0.07 x LC6tr =
'Chw»1s8reaPPrMp6ateve9ulaledlh ftffanfT
1=ronr Fai[ •>f enter Bre t£teRigq m eun6�
n'SaMr t•.
• h!. Anshlale.
If the reeelving abeam concentratlon is Waste
eracceptabieionuse
'hereon in%esponsihleCti Berga
N/aammeFt'r
S®.
�Ersmn�ornple9ngTdrie �(fialRarent
Name(print) .
$igna4ns
$Nevi suMnitta: Mdsk* ofWeterfj.MW
Aquahs Tenlca v unit
1621 M8B Tetvke Cellar
R e b, HC.2 gI;LJM
Affir. Todd Chriatannsse
AW.Q..Form 101(612600;
f6770 P.008

JAN.10'2006 09:91 628-667-6969 BASF #6770 2.009
g copper, zinc, or Mmtnhan ere present hr 8tapropaseel'61nCidal Compou
be used for each metal MUM metal cornppumf pteserd In the Modde. G:
IM M,*WB laaseoht jFIM, and the Cerlearraf$iem W the metal cCmpaW
ler,eeery Mala'I yrOSOBOn theblodde.
_ Gfia�icaP Furmela M�Ie .�arN IaMMS br FonmdaN
MALE
Dosage rate of Bfucide•(OR( (from page l;
ON = gMmYdag ..
AAoeragaVagY VAschorge(A'bb)*o%bpugs 7'Y•
AtM = mil5c¢g90oBa/&y .
Discharge Concentration (Deb of Bloclde
29ram IdaA omm
.� R mmbngeHorraidayy '`
. Convert mC temiavegramslllIDr(ppbfr
A7C�ggdJ = 9]G (gramafmlllbn gan 2 _..__..__ Awn. _
Calmlarogrefmcgor, bf metal lnAtra maiaf-oorkBlnirrg esnrytwnd (Mr.
. - 'FYd tire
CWCulafe titefmbgbn Cf M"W in the biocidaf comirwnd (B)- -
HF = MF x = x ..�( .%
�+olwlate fhecanwnlreffbn nfinemt hogiedisWaige (Mj:, ,-
Me DC BF= ugflz
MAC G M z 1vvcAO = ugn x loo %
3legniatarlNmttatlonb%meral gfrem'4blava wgll

of North Carolina
rtment of Environnnu11t
iatural Resources
in of Water Quality
Michael F. Easley, Governor I
Willam G. Ross Jr„ Secretary
Alan Klimek, P.E., Director
September 17, 2002
MR. JACK A. DELLINGER , PHD
1451 SAND HILL RD
ENKA, NC 28728
94
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
BASF CORPORATION-ENKA
BUNCOMBE COUNTY
PERMIT NO: NC0000299
LV 02-308
Dear Mr. Dellinger:
This letter is to acknowledge receipt of check No. 00376002 in the amount of $355.50 received from
you dated August 28, 2002. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations or Permits.
If you have any questions, please call Robert Farmer at [phone].
Sincerely,
�l
—�Coleen Sullins, Chief
Water Quality Section
Cc: Enforcement File #: LV 02-308
ARORegional Office Supervisor
Central Files
ii(wffU �`-' 4 "UH,1.
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

��S#NC0000299/BASF]
Subject: [Fwd: NPDES #NC0000299/BASF]
Date: Thu, 08 Aug 2002 14:16:32 -0400
From: Tom Belnick <[e-mail]>
To: Robert Farmer <[e-mail]>
CC: Roger Edwards <[e-mail]>,
Charles Weaver <[e-mail]>
fyi... Robert- this email serves as their rescission request.
Mailto:[e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
Subject: Re: NPDES #NC0000299/BASF
Date: Thu, 8 Aug 2002 13:30:39 -0400
From: Raymond L Ackerman <[e-mail]>
To: Tom Belnick <[e-mail]>
CC: Jack A Dellinger <[e-mail]>
Yes, Tom we finally did it! and all systems are going well. Please activate
the rescission process fo us; and thanks for your support and patience
through out this project.
Ray Ackerman
Tom Belnick
<tcm.belnick®ncm To: Raymond L Ackerman
ail.neb cc:
Subject: NPDES #NC0000299/BASF
08/08/2002 09:51
AM
Hi Ray- Congratulations on completing the connection to MSD Buncombe on
7/31/021 At this point I assume you want .your NPDES permit rescinded,
so that annual fees and compliance reporting requirements will be
stopped. Please let me know by email response, and I'll foward to the
NPDES Compliance Unit, which actually carries out the rescission steps.
Mailto:tom.belnickoncmail.net
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
1 of2 8/9/2002 7:45 AM

Subject: BASF rescission
Date: Mon, 26 Aug 2002 07:50:41 -0400
From: Roger Edwards <[e-mail]>
Organization: NC DENR - Asheville Regional Office
To: Robert Farmer <[e-mail]>
Robert,
BASF no longer discharges to surface waters. The connection to NSD was
completed on July 31, 2002. Proceed with the rescission of their NPDES
permit, NC0000299.
Thanks,
R. Edwards
Roger Edwards - Roger.Edwardsoncmail.net
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Roger Edwards <RoRcr.Edwards@ncmail net>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
1 of 1 8/26/2002 8:02 AM

State of North Cara
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
August 19, 2002
Ray Ackerman
BASF Corporation -Enka
1451 Sand Hill Rd
Enka NC 28728
NCDENR
NORM CAROLINA DEPARTMENT OF
ENVIRONMENT MD NxruA RasoURCES
AUG ?
Subject: Acknowledgement of Rescission Request
BASF Corporation -Enka
NPDES Permit No. NC0000299
Buncombe County
Dear Ray Ackerman
This is to acknowledge receipt of your request that NPDES Permit No. NC0000299
be rescinded. Your request indicated that this permit is no longer needed.
By copy of this letter, I am requesting confirmation from our Asheville Regional
Office that this permit is no longer needed. After verification by the Regional Office that
the permit is no longer needed, NPDES Permit No. NC0000299 will be rescinded.
If there is a need for any additional information or clarification, please do not hesitate
to contact Robert Farmer at [phone], ext. 531.
Sinc rely,
yr
E. Shannon Langley, Supervisor
Point Source Compliance/ Enforcement Unit
cc:
Point SourceBranch- Dave Goodrich - w/attachments
Point Source Branch - Robert Farmer - w/attachments
Central Files- Wattachments
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 5o%recycled/ 10%post-consumer paper

,BASF]
Subject: [Fwd: NPDES #NC0000299/BASF] -
Date: Thu, 08 Aug 2002 14:16:32 -0400
From: Tom Belnick [e-mail]>
To: Robert Farmer <[e-mail]
CC: Roger Edwards <[e-mail]>,
Charles Weaver <[e-mail]>
fyi... Robert- this email serves as their rescission request.
hIail to:tom.bel ni [e-mail]
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
Subject: Re: NPDES #NC0000299BASF
Date: Thu, 8 Aug 200213:30:39 -0400
From: Raymond L Ackerman <[e-mail]>
To: Tom Belnick <[e-mail]>
CC: Jack A Dellinger <dellinj @basf-corp.com>
Yes, Tom we finally did it! and all systems are going well. Please activate
the rescission process fo us; and thanks for your support and patience
through out this project.
Ray Ackerman
Tom Belnick
<tom.belnick@ncm To: Raymond L Ackerman
ail.net> cc:
Subject: NPDES #NC0000299/BASF
08/08/2002 09:51
AM
Hi Ray- Congratulations on completing the connection to MSD Buncombe on
7/31/02! At this point I assume you want your NPDES permit rescinded,
so that annual fees and compliance reporting requirements will be
stopped. Please let me know by email response, and I'll foward to the
NPDES Compliance Unit, which actually carries out the rescission steps.
Masi ate: tom.bel.ni.ckCancmail.net
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: (919) 733-SD83 ext. 543
Fax: [phone]
SA pl*d
1 of 2 8/8/02 3:12 PI

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional. Office
Michael F. Easley, Governor
Wiliam G. Ross, Sr., Secretary
Alan D. Klimek, P. E., Director
Division of Water Quality
WATER QUALITY SECTION
August 19, 2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jack A. Dellinger, PhD
General Manager
BASF CORPORATION
Sand Hill Road
Enka, North Carolina 28728
46&
NCDENt
NORTH CENVIRONMENT AND NNl1RhL. RESOURCES
SUBJECT: Notice of Violation and Assessment
of Civil Penalty for Violations of N.C.
General Statute 143-215.1(a)(6)
and NPDES Permit NC0000299
BASF CORPORATION
Case No. LV 02 - 308
Bun ombe County
Dear Mr. Dellinger:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$355.50 ($250.00 civil penalty + $105.50. enforcement costs) against BASF Corporation.
This assessment is based upon the following facts: a review has been conducted of the
discharge monitoring report (DMR) submitted by BASF Corporation for the month of March, 2002.
This review has shown the subject facility to be in violation of the discharge limitations and/or
monitoring requirements found in NPDES Permit NC0000299. The violations, which occurred in
March, 2002 are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that BASF Corporation violated
the terms, conditions or requirements of NPDES Permit NC0000299 and N.C.G.S. 143-
215.1(a)(6) in the manner and extent shown in Attachment A. A civil penalty of not more than
twenty-five thousand dollars ($25,000.00), in accordance with the maximums established by
N.C.G.S. 143-215.6A(a)(2), may be assessed against a person who violates the terms, conditions
or requirements of a permit required by N.C.G.S. 143-215.1(a).

Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural Resources
and the Director of the Division of Water Quality, I, Forrest R. Westall, Division of Water Quality
Regional Supervisor for the Asheville Region, hereby make the following civil penalty assessment
against BASF Corporation:
$ 250.00 For 1 of the 1 violations of G.S. 143-215. 1 (a)(6) and
NPDES Permif No. NC0000299, by discharging waste into the
waters of the State in violation of permit daily maximum effluent
limits for Biochemical Oxygen Demand (BOD).
$ 250.00 TOTAL CIVIL PENALTY
$ 105.50 Enforcement costs.
$ 355.50 TOTAL AMOUNT DUE

Pursuant to G.S..143-215.6A(c), in determining the amount of the penalty I have taken into
account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health,
or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by non-compliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and
Natural Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Please submit payment to the attention
of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
2. Submit a written request for remission or mitigation including a detailed justification for
such request:
A request for remission or mitigation is limited to consideration of the reasonableness of
the amount of the penalty and is not the proper procedure for contesting the accuracy of
any of the statements contained in the assessment letter. Because a remission request
forecloses the option of an administrative hearing, such a request must be accompanied
by a waiver of your right to an administrative hearing and a stipulation that there are no
factual or legal issues in dispute. You must execute and return to this office the attached
waiver and stipulation form and a detailed statement, which you believe establishes
whether:

C7 (�
(a) one or more of the civil penalty assessment factors in G.S. 143B-262.1(b) were wrongfully
applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for remission must be
submitted in writing. The Director of the Division of Water Quality will review the information
during a bimonthly enforcement conference and inform you of his decision in the matter of the
remission request. His response will provide details regarding case status, directions for payment
and provision for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions. Please be advised that the Committee can not consider
information that was not part of the original remission request considered by the Director and
therefore, it is very important that you prepare a complete and thorough statement in support of
your request for remission.
W.
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an
administrative hearing. This request must be in the form of a written petition to the Office of
Administrative Hearings and must conform to Chapter 150B of the North Carolina General
Statutes. You must File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601

(-)
Failure to exercise one of the options above within thirty days, as evidenced by a date
stamp (not a postmark) indicating when we received your response, will result in this matter being
referred to the Attorney General' Office with a request to initiate a civil action to collect the
penalty.
Please be advised that any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty. If you have any questions about this civil
penalty assessment, please contact Mr. Roger C. Edwards of the Asheville Regional Office at
828/251-6208.
O O�
( ate)
ATTACHMENTS
Xorrest R. Westall
Water Quality Regional Supervisor
Asheville Region
Division of Water Quality
cc: Roger Edwards w/ attachments
Point Sources Compliance/Enforcement Unit w/ attachments
Central Files w/ attachments

ATTACHMENT A
BASF Corporation
NPDES Number NC0000299
Case Number LV 02.308
Limit Violations, March 2002
Daily Maximum Limit Violations
Parameter
Date
Reported Value
Limit
Units
BOD
317/02
376
291
lb/day

STATE OF NORTH CAROLINA
ENVIRONMENT
COUNTY OF BUNCOMBE
IN THE MATTER OF ASSESSMENT )
OF CIVIL PENALTIES AGAINST )
BASF CORPORATION )
PERMIT NO. 0000299 )
DEPARTMENT OF
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. LV 02 - 308
Having been assessed civil penalties totaling $355.50 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated August 13, 2002, the
undersigned, desiring to seek remission of the civil penalties, does hereby waive the right
to an administrative hearing in the above -stated matter and does stipulate that the facts
are as alleged in the assessment document.
This the
day of 2002.
Al
ADDRESS
TELEPHONE

DMR REVIEW RECORD
Facility: BASF Corporation Permit/Pipe No.: 001 MonthNear: 03/02
Daily Violations
Date Parameter Permit Limit/Type DMR Value %Over Limit
3/7/02 BOD 2911b/day daily 376lb/day 23%
Completed by: Date: B/,3/z
i

DIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT
Violator: BASF Corporation
County: Buncombe
Case Number: LV 02 - 308
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private propwly resulting from the violation;
of significant ( ) moderately significant () significant
( ) very significant ( ) extremely significant
2) The juration and gravity of the violation;
( of significant ( ) moderately significant (.) significant
( ) very significant ( ) extremely significant
3) Theoffect on ground or surface water quantity or quality or on air quality;
( of significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
4) Thepost of rectifying the damage;
of significant ( ) moderately significant () significant
( ) very significant ( ) extremely significant
5) The amount of money sav y non-compliance;
() not significant Kimoderately significant () significant
( ) very significant ( ) extremely significant
6) Whnot er the violation was committed willfully or intentionally;
( significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
7) The prior record of the violator in complying or failing to comply with programs over which the
Environme01 Management Commission has regulatory authority; and
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
8) The�ost to the State of the enforcement procedures.
( not significant () moderately significant () significant
( ) v ry significant O extremely significa t
Date rest R. es ll, Water Quality Supervisor
Asheville Regional Office
REMISSION FACTORS
() Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment
of the petitioner;
( ) Whether the violator promptly abated continuing environmental damage resulting from the
violation;
() Whether the violation was inadvertent or a result of an accident;
() Whether the violator had been assessed civil penalties for any previous violations; and
() Whether payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Alan D. Klimek P. E., Director
Division of Water Quality

PHONE:
N. C. DEPARTMENT -'OF ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
59 WOODFIN PLACE
ASHEVILLE, NORTH CAROLINA 28801
828/251-6208 FAX: [phone]
TO:
FAX #:
FROM: 3z ZE 9At2- I5,
DATE:
# OF PAGES INCLUDING THIS COVER:
MESSAGE: If questions, please call 828/251-6208.

BASF Corporation (I) I BASF
August 2,2002
Mr. Roger Edwards
Waste Water Consultant
NC DENR
59 Woodfin Place
Asheville, NC 28801 — 2414
Re: NPDES Permit NC 0000299
Dear Mr. Edwards:
AUG - 5 2002
This memo is to inform you that BASF has discontinued the discharging of waste
water to Hominy Creek (outfall #001 per the referenced permit), effective the 1st
of August. Flow was actually stopped on the evening of July 31". We are now
sending all of our waste water to the Metropolitan Sewerage District of
Buncombe County. They have issued us Permit Number S-072-02 for this
discharge; it is effective August 1, 2002.
Our NPDES Permit also covered outfall #002, non -contact cooling water
discharged through our East Ditch. This water has been commingled with the
several streams from condensers and cooling towers, which have been permitted
under our general discharge Permit Number NCG50067. This permit has recently
been reissued to also be effective August 1, 2002.
MSD's Engineering personnel were here yesterday, and Mr. Payne was at our
site today to obtain an initial TSS and BOD sample; all parties seemed satisfied
with the tie-in and start-up conditions.
My thanks to you and the DENR personnel in Raleigh for you exhaustive
patience and assistance in bringing this project to a satisfactory if not swift
conclusion.
Sincerely,
/ cry V2,�
Ray Ackerman
Environmental Manager
Sand Hill Road, P.O. Box 669, Enka, North Carolina 28728-0669 [phone]

State of North Carolina,
Department of Environs !ant
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Alan W. Klimek, P.E. Director
July 26, 2002
RAY ACKERMAN
BASF CORPORATION
SAND HILL ROAD
ENKA, NC 28728
j
:•
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
II II %I I -11 I?
Subject: Reissue -NPDES Wastewater Discharge Permit
BASF Corporation -Enka
COC Number NCG500607
Buncombe County
Dear Permittee:
Your facility was recently granted coverage under wastewater discharge general permit NCG500000. This letter
serves as your notification that the Division of Water Quality (DWQ) has reissued the general permit and that your
facility's coverage will continue under the conditions of the reissued general permit. Please review the new permit
and technical bulletin to familiarize yourself with the changes in the reissued permit. In addition, DWQ is
forwarding herewith a reissued wastewater discharge general permit Certificate of Coverage (COC) for your
treatment facility. This COC is reissued pursuant to the requirements of North Carolina General Statute 143-215.1
and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection
Agency, dated May 9, 1994 (or as subsquently amended).
The following information is included with your permit package:
* A copy of the Certificate of Coverage for you treatment facility
* Acopy of General Wastewater Discharge Permit NCG500000
* A copy of a Technical Bulletin for General Wastewater Discharge Permit NCG500000
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Aisles Lau of the Central Office Storawater
and General Permits Unit at [phone], ext. 578
Sincerely,
�itn.eu�y kjrr�vRe�i
for Alan W. Klimek, P.E.
cc: Central Files
Stormwater & General Permits Unit Files
Asheville Regional Office
1617 Mail Service Center, Raleigh, North Carolina 27699.1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

2002 14:26 #2499 P.001/003
POper C^�WarQ
Fro M : /har� �e 1ee r-e^4.` yolKs
,3 f 4g
JUL 1 0 2,002

JUL. 09'2002 14:26
BASF Corporation
#2499 2.002/003
BASF
July 9, 2002
Mr. David Goodrich
Supervisor
NCDF_NRIDWQ/NPDES UNIT
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Goodrich:
This is in response to your request of Ray Ackerman for a letter detailing the
current status of the MSD project, But first [at me express my appreciation to you
and your staff for their understanding and support of our efforts to discontinue the
operation of our WWTP and discharge to the local POTW. This has been an
expensive and difficult undertaking given the complexity of the situation and the
number of parties involved. BASF has made a concerted effort to keep the local
DENR Office informed and Involved, and will continue to do so.
The project involves the following parties;
BASF Corporation
Colbond, Inc.
Biltmore Farms, Inc.
Fletcher Partners, Inc.
The Enka Village Home Owners
BASF, Colbond, and The Enka Village each have a Tine that will discharge to a
MSD sewer line. BASF's line is ready to use and Colbond's line will be completed
when The Village waste is removed from their lift station. Colbond, Biltmore
Farms, and Fletcher Partners own the parcels of land through which the line from
Enka Village traverses. BASF built and currently owns the line. The current delay
is the satisfaction of MSD on the easement from Biltmore Farms and the
satisfaction of the County Clerk's office with the proper signature on the deed
transferring ownership of the Village line from BASF to MSD. The Colbond
easement and the Fletcher Partners easement have been accepted by MSD.
Based upon our current information, the transfer of the deed from BASF to MSD
should be properly executed by the and of this week and MSD will have an
acceptable easement from Biltmore Farms by July 19t6.
snntl HIII Roes, P.O. Bea M, Enka, Nam 0arollno 2672&0669 (6261667.7110

2002 19:26 02999 P.003/003
2
Once these legal issues are resolved and MSD gives us permission to complete
the tie-in of the village line, we anticipate we will be discharging to MSD by the
middle of August. Given the history of the project so far, however, we would
request the extension of our NPDES Permit through the end of August.
Again, let me thank you for your understanding and assistance in the satisfactory
completion of this project.
Sincerely,
eact.
General Manager

Re: [Fwd: NPDES Permit Extension]
Subject: Re: [Fwd: NPDES Permit Extension]
Date: Tue, 18 Jun 2002 07:27:52 -0400
From: Roger Edwards <[e-mail]>
Organization: NC DBNR - Asheville Regional Office
To: Tom Belnick <[e-mail]>
Tom,
Thanks for handling this extension. The 60 days should be more than adequate
time to get everything completed. Again, thanks.
R. Edwards
Tom Belnick wrote:
> fyi... sounds like MSD has been dragging this one along. I don't think
> there will be a problem with an administrative extension.
> __
> Mailto:[e-mail]
> N.0 DENR-DWQ/NPDES Unit
> 1617 Mail Service Center, Raleigh NC 27699-1617
> Work: [phone] ext. 542
> Fax: [phone]
------------------------------------------------------------------------
> Subject: NPDES Permit Extension
> Date: Mon, 17 Jun 2002 15:32:45 -0400
> From: Raymond L Ackerman <[e-mail]>
> To: [e-mail]
> Mr. Belnick,
> Needless to say it is both embarrassing and frustrating for me to ask, but
> I find myself totally at the mercy of others in discontinuing the operation
> of our WWTP. We will need to further extend the period of our permit. MSD
> is requiring the completion of four easements pursuant to the new "village
> line" and as you might expect, they are being held up by all the lawyers
> for the five parties concerned ( MSD, BASF, Colbond, The Fletcher Group,
> and Bil tmore Farm, Inc.). With the exception of the two new manhole that
> will serve the Village, BASF has completed all the work necessary to send
> all of the waste to MSD. (We actually had our part done by mid -May as
> originally expressed to you as a completion date). I have discussed this
> with Roger Edwards of the Asheville Water Quality Section and he has been
> in contact with MSD. Re has suggested that I request a 60 day extension of
> our permit, which should allow for all the legalities and our small amount
> of construction work to be completed. Your further patience and
> cooperation in this matter is greatly appreciated.
> Sincerely,
> Ray Ackerman
Roger Edwards - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
1 of2 6/18/2002 7:40 AM

State of North Carolina
Department of Environmt
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
Willam G. Ross Jr., Secretary
Gregory J. Thorpe, PhD., Acting Director
W�
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
May 23, 2002 , st
�I u
JACK A. DELLINGER
1451 SAND HILL RD
ENKA, NC 28728
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
BASF CORPORATION-ENKA
BUNCOMBE COUNTY
PERMIT NO: NC0000299
LV 02.113
Dear Dear Mr. Dellinger:
This letter is to acknowledge receipt of check No.00320581 in the amount of $1,105.50 received from
you dated May 10, 2002. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations or Permits.
If you have any questions, please call at [phone],
Sincerely,
RUC AL"
�� Coleen Sullins, Chief
Water Quality Section
Cc: Enforcement File #: LV 02-113
ARORegimud Office Supervisor
Central Files
1617 Mail Service Center, Raleigh, NC 27699.1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycledt10% post -consumer paper

BASF Enka Plant; NC0000299; Buncombe County
Subject: BASF Enka Plant; NC0000299; Buncombe County
Date: Fri, 24 May 2002 14:31:17 -0400
From: Tom Belnick <[e-mail]>
To: [e-mail]
CC: Roger Edwards <[e-mail]>
Ray- Based on our conversation today, BASF will need another 30 days to
complete the connection to MSD Buncombe County. The current BASF NPDES
permit expires 5/31/02. We will maintain this permit in active mode for
another 30 days to allow project completion. All terms and conditions
contained in the original permit remain unchanged and in full effect.
Mailto:tom.belnick®ncmail.net
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
1 of 1 5/24/2002 2:36 PM

State of North Carolina I
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
WATER QUALITY SECTION
April 29, 2002
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jack A. Dellinger, PhD
General Manager
BASF CORPORATION
Sand Hill Road
Enka, North Carolina 28728
Ai TkT4
NCDENR
N.a. CAROUNA DEIIRr.ENT of
ENVIRONMENT AND NMUAAI RESOURCES
SUBJECT: Notice of Violation and Assessment
of Civil Penalty for Violations of N.C.
General Statute 143-215.1(a)(6)
and NPDES Permit NC0000299
BASF CORPORATION
Case No. LV 02 - 113
Buncombe County
Dear Mr. Dellinger:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$1,105.50 ($1,000.00 civil penalty + $105.50. enforcement costs) against BASF Corporation.
This assessment is based upon the following facts: a review has been conducted of the
discharge monitoring report (DMR) submitted by BASF Corporation for the month of November
2001. This review has shown the subject facility to be in violation of the discharge limitations
and/or monitoring requirements found in NPDES Permit NC0000299. The violations, which
occurred in November 2001, are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that BASF Corporation violated
the terms, conditions or requirements of NPDES Permit NC0000299 and N.C.G.S. 143-
215.1(a)(6) in the manner and extent shown in Attachment A. A civil penalty of not more than
twenty-five thousand dollars ($25,000.00), in accordance with the maximums established by
N.C.G.S. 143-215.6A(a)(2), may be assessed against a person who violates the terms, conditions
or requirements of a permit required by N.C.G.S. 143-215.1(a).

Based upon the abq-^ findings of fact and conclusiong-( law, and in accordance with
authority provided by the Secretary of the Department of Envii , ment and Natural Resources
and the Director of the Division of Water Quality, I, Forrest R. Westall, Division of Water Quality
Regional Supervisor for the Asheville Region, hereby make the following civil penalty assessment
against BASF Corporation:
$ 1,000.00 For 1 f the 1 violations of G.S. 143-215.1(a)(6) and NPDES
Permit No. 14C0000299, by discharging waste into the waters of
the State in violation of permit monthly average effluent limits
for total suspended solids.
$ 0 For 1 of the 1 violations of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0000299, by discharging waste into the
waters of the State in violation of permit daily maximum effluent
limits for total suspended solids.
$ 1.000.00 TOTAL CIVIL PENALTY
$ 105.50 Enforcement costs.
$ 1,105.50 TOTAL AMOUNT DUE

Pursuant to G.S. 143-215.6A�oj in determining the amount of the penalty I have taken into
account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health,
or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by non-compliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following
Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and
Natural Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Please submit payment to the attention
of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Loll
2. Submit a written request for remission or mitigation including a detailed justification for
such request:
A request for remission or mitigation is limited to consideration of the reasonableness of
the amount of the penalty and is not the proper procedure for contesting the accuracy of
any of the statements contained in the assessment letter. Because a remission request
forecloses the option of an administrative hearing, such a request must be accompanied
by a waiver of your right to an administrative hearing and a stipulation that there are no
factual or legal issues in dispute. You must execute and return to this office the attached
waiver and stipulation form and a detailed statement, which you believe establishes
whether:

(a) one or more of the ci("" enalty assessment factors in G.S^"'�3B-262.1(b) were wrongfully
applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(a) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for remission must be
submitted in writing. The Director of the Division of Water Quality will review the information
during a bimonthly enforcement conference and inform you of his decision in the matter of the
remission request. His response will provide details regarding case status, directions for payment
and provision for further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions. Please be advised that the Committee can not consider
information that was not part of the original remission request considered by the Director and
therefore, it is very important that you prepare a complete and thorough statement in support of
your request for remission.
NV
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an
administrative hearing. This request must be in the form of a written petition to the Office of
Administrative Hearings and must conform to Chapter 150B of the North Carolina General
Statutes. You must File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601

Failure to exercise no of the options above within thirty ays, as evidenced by a date
stamp (not a postmark) indicating when we received your response, will result in this matter being
referred to the Attorney General' Office with a request to initiate a civil action to collect the
penalty.
Please be advised that any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty. If you have any questions about this civil
penalty assessment, please contact Mr. Roger C. Edwards of the Asheville Regional Office at
828/251-6208.
(D te)
ATTACHMENTS
/Forre s
Water Quality Regional Supervisor
Asheville Region
Division of Water Quality
cc: Roger C. Edwards w/ attachments
Point Sources Compliance/Enforcement Unit w/ attachments
Central Files w/ attachments

ATTACHMENT A 7)
BASF CORPORATION
NPDES Number NC0000299
Case Number LV 02-113
Limit Violations, November 2001
Monthly Average Limit Violations
Parameter Reported Value Limit Units
TSS 289 209 Ibs/day
Daily Maximum Limit Violations
Parameter Date Reported Value Limit
TSS 11/07/01 575 565
Units
Ibs/day

STATE OF NORTH CAR06,,
COUNTY OFBUNCOMBE
IN THE MATTER OF ASSESSMENT )
OF CIVIL PENALTIES AGAINST )
BASF CORPORATION )
PERMIT NO. NC0000299 )
DEPARTMLNT OF ENVIRONMENT
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. LV 02 - 113
Having been assessed civil penalties totaling $1,105.50 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated April 29, 2002, the
undersigned, desiring to seek remission of the civil penalties, does hereby waive the right
to an administrative hearing in the above -stated matter and does stipulate that the facts
are as alleged in the assessment document.
This the
day of 2002.
L:i9
ADDRESS
TELEPHONE

DMR REVIEW RECORD
Facility: BASF Corporation Permit/Pipe No.: 001 Month/Year: 11/01
Monthly Average Violations
Parameter Permit Limit DMR Value % Over Limit
TSS 209 289 38
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value %Over Limit
11/07/01 TSS 565lbs/day 575 Ibs/day, 2.0
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported # of Violations
Other Violations
Completed

r'1)
DIVISION OF vVATER QUALITY - CIVIL PENALTY ASSESSMENT
Violator: BASF Corporation
County: Buncombe
Case Number: LV 02 - 113
ASSESSMENTFACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private prop resulting from the violation;
( of significant ( ) moderately significant () significant
( ) very significant ( ) extremely significant
2) The ration and gravity of the violation;
( of significant ( ) moderately significant () significant
( ) very significant ( ) extremely significant
3) The Vect on ground or surface water quantity or quality or on air quality;
( t significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
4) The lost of rectifying the damage;
act significant ( ) moderately significant () significant
( ) very significant ( ) extremely significant
5) The amount of money save y non-compliance;
() not significant ( oderately significant ( ) significant
( ) very significant ( ) extremely significant
6) Wh er the violation was committed willfully or intentionally;
( of significant O moderately significant O significant
( ) very significant ( ) extremely significant
7) The prior record of the violator in complying or failing to comply with programs over which the
Environrn r1lanagement Commission has regulatory authority; and
( of significant () moderately significant () significant
( ) very significant ( ) extremely significant
S) The st to the State of the enforcement procedures.
of significant ( ) moderately significant () significant
( ) very significant () extremely signifi
D e Wrest R. Westall, VVat6r Quality Supervisor
Asheville Regional Office
REMISSION FACTORS
( ) Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment
of the petitioner;
( ) Whether the violator promptly abated continuing environmental damage resulting from the
violation;
() Whether the violation was inadvertent or a result of an accident;
() Whether the violator had been assessed civil penalties for any previous violations; and
() Whether payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality

,2 10: 21
#2650 2.002/005
dASFCorporation r'SAW
March 27, 2002
Central Files
NC Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699�1617
Dear Sir:
REFERENCE: Priority Pollutants Monitoring Report 1" Qtr. 2002
Enclosed are two copies of the Reporting Form "A" for the Annual Pollutant Monitoring
Requirement of our NPDES Permit # NC 0000299.
Sincerely,
1aa-4Lft--
viro
R Ackerman
E nmental Manager
Attachment
Sand HIII Ramd, P.O. SOX Oft Enka, NOIIh Cemlina 28728-0089 (828) 8074119

AOG.0912002 10:21 #2650 P.001i.
F,1m, NC 29729
PMma: 823667.7118
Fm 62"06969
Te ,� f _Fsc as/ �nV.i L
FIO Itl d
rm: s
D urgent DForRMw. DPM=Cmmerg r3FIMora* DR@mR6qM1„
CnY� v 'u . . . . .. . . . .. .. . .

-002 10:25 #2650 P.005/005
7
Pecs ARerymel8ervlcea, Inc.
FEW
ace.OmAvoumlle.. Suite 100
" CZW°AnalXicaf" P704.E7590E
w,pce700awm FU.704.875901
to Pmj"t Dumber: 9230360
Client.
Penjent ID: BASF
93273.0E
Dab Bampl.e 90, 931129902
PMJ40t Sample Nurbee:
9230360.001
Date Cottontail 02/15/02 4100
Client "In 10, Ooi 0111MA
Matrix:
Wear.
Date Received: 02/18/02 41,63
Pe�..wtera
a..,,,.. 1InI F9 Raam•t aa-Le Motion
seas
vrnn
m.
ybhate BEg-ldmit
4,6•pWtro-2-m4rhylphmel
ND
vp/1
90.
1.0
02/21./02
16:04
"0
534.52.1
•R,4•pinl.teephen0l
ND
ug/1
50.
1.0
02/21/92
26:04
RPO
51-28-5.
a,4-pinitmhelmee
RD
to/1
10.
1.0
02/21./02
16:04
APO
1.21.14.2
1,6-aW.tmmlvenr
RD
aN/1
10.
1.0
o2/21/02
a6:04
RHO
606-20-2
pi-n-sctylphthalat,
No
vg/1
10.
1.0
02/21/02
16,04
IN
17.7.04-0
hie (1.8GhylhrEyllykthalate
25.
tell
10.
1.0
02/21/02
16;04
IN
117.61: 7 1,M
Pivexanthana
NO
ug/1
10.
1.0
02/21/02
16:04
NP/
206.44.0
P1v=m
ND
ug/1
10.
1.0
02/21/09
16:04.
NO
06.73.7
7aawwblom-4,3-bmeadiene
N0
ag/1
10.
2.0
02/21/02
16:04
RPO
47-6e4
Ma,:seh1nr06memr
NO
vR/1
10.
1.0
02/21/02
26,04
W'O
110.74-1
Mereehl0rary0l0ymtadiene
No
ep/1
Ia.
4.0
02/21/02
16,04
Ran
77.47.4
getashlOtaekhave
ED
vB/1
10.
4.0
02/21/02
29,04
too
67.72-1
2nMno (1, 1, 9-cd)pyrme
ND
uB/1
10.
2.0
02/21/02
16:04
00
1.93.39.9
1mvpb0mne
90
Vol,
to.
1.0
02/21/02
10,04
Man
98-99-1
Nephtbalam
DD
vg/1
ID.
IA
02/21/07
16,c4
"a
91-20-3
Rltmbencene
m
uP/1
to.
1.0
02/21/02
16,04
RPd
90.93.3
2-Nitx'Vhenol
m
UP/1
10.
1.0
02/11./0I
16,04
APO
80.16-6
4-N2LtOpheP01
'Dr)
Pg/1
so.
1.0
02/21./02
16104
RPO
1D0.02.7
R•Mitxse0diaetbyleEime
N0
vg/l
10•
1.0
02/21./02
Mee
RP0
62.76-9
N-Mikxsam di•n•pxepylemiae
DO
u9/1
Ia.
1.0
02/21/02
16,04
IN
621.64.7
M•Miuvoo iphm mama
ND
eg/l
10.
1.0
03/21/02
16;04
RPO
89.30.6
P�ter16ar0phm01
ND
ep/1
50.
1.0
03/R1/uR
1604
Dan
87-06-5
Pbevaathmane
N0
ug/l
to.
1.0
02/21/03
Mod
Ran
IS-01.1
7hen01
DD
eg/1
10.
1.0
02/21/07
16104
"a
108.05-2
pytma
ED
uR/1
10.
1.0
02/21/92
16:04
Ran
129.00.0
1,2,44rich10rabeneene
lm
uD/1
10,
1.0
02/21/02
19:04
RP9
120-e2.1
2,4,6-cr2ahlacophonal
DN
mg/1
10.
1.0
02/21/02
16:04
Ron
so-06.2
Rittobenmam49 [a)
34
8
1.0
02/21/01
16,04
09
4166-60-0 4
a•nmmrobiph.nyl (a)
34
1
1..0
02/21./02
16,04
Rog
921.00.8 4
l6rphm,y2•dl4 (9)
39
b
1.0
02/21/02
16,04
Pea
1718.51.0
a-neormhmel (0)
s2
1.0
02/21/02
16:04
Rea
367.22.4
2,4.6.4YibroMbeasl (St
0
F
1.0
oR/21/02
26:04
Pea
4
new ID t".ted
oR/20/02
ac 6emivalabilas
pea5leidm in water. by OR
Prappletinni;
BPA 408
By / EFA 608
A7.dv3n
0.27
v0/1
0.050
1.0
0/27/02
COE
2DD-00.2
alpha-BRC
to
tell
0.860
1.0
02/27/02
CIE
31944-6
n.0., 01/15/02
P.4., 2
Lt0�"OModffim"on1°a
REPORT OF LABORATORY
ANALYSIS
WUWJRS
NC Wastewater 12
KvndnL°0b"owater 9090
NC 110000 Water 37706
7%report
shag
am be reproduced,
except to full,
VA Drinking Water 213
SC Mao
Without the written ounsent of Pats Analoold Services, Ian.
M NELAP E87627

.002 10:22 #2650 P.003/005
QUARTERLY EFFLUENT MONITORING REPORT
March 27, 2002 FACILITY NAME: SA5F Fibem Enka Plant
NPCES PERMIT NO: NO 0000290

AUG.09'2002 10:24 /^`+y #2650 P.004/00,
l y
Nge2
Note:
All samples are grab samples taken an February 171h, py Glenn Howell of pose Analyticel, Inc.
The low that day was 0.495 MGO.
I cerUythal', this report Is accurate and complete to the beet Of my knowledge.
Raymond L. Acicarman
Operator In Responalble Charge

t0111A��rF90
O(iJW r
O�C
Mr. Ray Ackerman
BASF Corporation
1451 Sand Hill Road
Enka, North Carolina 28728
Dear Mr. Ackerman:
Michael F. Easley, Governor
( ) William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, PnD.
Acting Director
Division of Water Quality
December 31, 2001
Subject: - NPDES Permit Modification
Permit No. N00000299
BASF- Enka Plant
Buncombe County
The subject individual NPDES permit issued on October 23, 1995 has been modified as follows:
• The permit expiration date has been administratively extended to May 31, 2002. This permit extension
will provide the permittee time to complete its wastewater connection to the Metropolitan Sewerage
District of Buncombe County. All other terms and conditions contained in the original permit and
subsequent modifications remain unchanged and In full effect.
Please find enclosed the revised Permit Cover Sheet, which will replace the old Permit Cover Sheet. This permit
modification is issued pursuant to the requirements of North Carolina General Statute 143.215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9,
1994 (and as subsequently amended).
If any parts, measurement frequencies or sampling requirements contained in this permit modification are
unacceptable to you, you have the right to an ad)udicatory hearing upon written request within thirty (30) days
following receipt of this letter. This request must be In the form of a written petition, conforming to Chapter 150E of
the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center,
Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding.
Please take notice that this permit is not transferable. Part II, EA. addresses the requirements to be followed in case
of change in ownership or control of this discharge. This permit does not affect the legal requirements to obtain other
permits which may be required by the Division of Water Quality or permits required by the Division of Land
Resources, Coastal Area Management Act, or any other Federal or Local governmental permits may be required.
If you have any questions or need additional Information, please contact Mr. Tom Belnick, telephone number (919)
733-5083, extension 543.
Sincerely,
Original Signed BY
[)avid A. Goodrich
Gregory J. Thorpe, Ph.D.
cc:
US EPA, Roosevelt Childress
Asheville Regional Office, Water Quality
Point Source Compliance
NPDES File
Central File
N. C. Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699.1617
[phone]
Customer Service:
1 800 623-7748

Permit No. NC0000299
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
BASF Corporation
is hereby authorized to discharge wastewater from a facility located at
Fiber Products Division- Enka Plant
1451 Sand Hill Road
Enka, North Carolina
Buncombe County
to receiving waters designated as Homony Creek in the French Broad River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth
in Parts I, II, III, and IV hereof.
The permit shall become effective December 31, 2001
This permit and the authorization to discharge shall expire at midnight on May 31, 2002
Signed this December 31, 2001
Original Signed By
David A. Goodrich
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

file://[Untitled
Ray - In accordance with your request below and following review of the laboratory data you faxed me on
11/14/01, please use this e-mail as approval for the addition of 4 gpd of contaminated groundwater from
BASF's soil vapor extraction process to BASF's wastewater treatment facility (NC0000299). The resulting
discharge to Hominy Creek, Class "C" waters in the French Broad River Basin should present no water
quality compliance problems. Waterquality standards assigned to this stream for Trichloroethene and
1, 1,2,2-Tetrachloroethane should not be threatened as result of this waste addition.
Please advise if you want to discuss this in more detail. Max
Raymond L Ackerman wrote:
Max,
We are generating approximately 4 gallons a day of contaminated ground water
from the SVE (Soil Vapor Extraction) System under building 660, the former
Marketing Tech Building now leased by A B-Tech (We still own the land under the
building). The water is collected in an 80 gallon knock out tank down stream of
the suction pump. I have faxed you the test results from Pace Analytical
Laboratory showing the contaminants to be 14 ppb of Chloroform, 4.5 ppb of
Trichloroethylene, and 140 ppb of 1,1,2,2,-Tetrachloroethane. I am requesting
permission to dump this ground water into our W WTP at the rate of approximately
8 gallons every two days.
Thanks for your attention to this request,
Ray
Max Haner - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Wood£m Place
Asheville, NC 28801
Tel: [phone]
.Fax: [phone]
1 of 1 11/15/2001 1:36 PM

l /
eF CORPORATION
Facsimile Cover Sheet
40870 P.001/003
l�
BASF
From: l a y e rAo
BASF Corporation .
.Sand Hill Read
Enka, NC 29728
Fax:. J �- Y. ,S G phone.
Phone: Fax:
Date:
Pages:
Subject:,
COMMENTS:
I

NOV.13'2001 15:44
l J n 40,
aceAnalytica!"
wvnvplDarabsmm
Pact Anmlyticai a ... Laos, Inc.
54 aavmecxoft px1v4
AplavLlla, NC 20001
Attn: me. Eeverly Mrinatold
Phone: [phone]
NoAloa4wcal,.
9BO *OyAmvn ,
ryWllmsMis NC..
Phan: 704.875.D092
Rr 704.875.Mt
Lab Project Mi ex: P227106
client Pnojeet 0: Bur/9324416
Lab Sample xa: 031022347 Froject Semple N=ben 92271.06-001 Date Collected, le/E3J01 10:30
Mont Demple ID: ODE 31ATEB Matxlx: Rotas Data aareived, 10/13/01 11:06
9-P�eser^ „•ReayltP,.._, Daniel, Ra➢➢P111dait Allyelon alT+aA fAS,�.o FtElste Rea-blusu
OC Vojstileg
VPlmtile Ealonanbom by 601 pr4p/Method:
SPA 601
/ EPA 601
Dicgloxnditluorometheue
MD
vg/1
1.0
1.0
].0/29/01
PM
75-71-8
ahlanouchnal
0
u0/1
2.0
1.0
10/29/01
PM
74-37-3
V1ayl ehlnride
tm
n01
1.0
1.0
1.a/29/al
PPM
75-01-4
Eromomethma
ND
xg/1
110
1.0
1.0/29/01
PM
7443-9
cbiomothere
m
ug/1
1.0
1.0
1.0/23/01
PPM
75-00-3
Triaglaxot].mxomaPdana
m
uT/1
1.0
1.a
10/29/01
MPH
75-60.4
1,1-Dichlamethnne
ND
ug/1
7..0
1.0
10/29/03.
PMP
15-35-4
Methy14a4 ehlmrl4e
Mo
ug/1
2.0
13
10/29/01
PM
75.09.2
txma•1, 2-Dicglosoeth4n4
N0
ug/1
1.0
1.0
10/29/01
PPM
156.60-5
1,3. DAchlemetb=0
MA
1,g/1
1.0
1.0
10/29/01
FPM
75-34.2
- Chl".f.m
14.
09/l
1.0
1.0
10/29/01
PPM
67.66.3
,
1,1,1-xrirl1ormetheue
RD
ug/1
1.a
1.0
10/20/01
PPM
71.55.6
Carbax totxachloxida
1,2-DLchlnmaeleae
Ne
Mn
ug/1
ug/1
119
1,0
1.0
1,0
10/29/01
10/29/02
➢PM
PPM
56-23-5
107.06-2
,Tx1.xh3.amntham : �Z:�WSt
hest
A.5
vg/1
1.0
1,0
10/29/01
PPM
79-a1.6
1,2-Dicklcrapmpaue i`
I,l,n+- Am
u9/1
l,a
1,0
10/29/01
PM
79-97-5
araaadicAloeumetlme
Mn
ug/L
S,a
1.0
10/29/01
➢➢M
75-27.4
eta-1,3-pichl... P..peoe
MD
n/1
1..0
l.a
10/29/oL
PPM
10061-a1-5
trine-1, 3•nicllorapxopeue
Nn
ug/1
110
i,a
10/29/01
PM
10061.02.6
1,12•Tr bLomoatbm4
0
h9/1
L,a
1.9
3Af29/01
FFM
79.00.5
Tetrechlcrnettme
MD
ug/1
110
1,0
3.0/29/P1
FPM
127.18-4
DSbromochlgxxmethaae
tin
ng/1
1.0
1.,0
1.0/29/01
PPM
124-48-1
Chlorogeusme
ND
lag/1
1.0
1.0
10/29/01
FIX
NB-90.7
Emmnform 1,,
(.a ND
ug/1
1.0
1.0
1e/29/01
PPM
75.25.2
.:111,2,2-Tetr.dhI6p thuha
:G94.r 140
ug/1
1.0
1.0
10/29/01
PPM
79-34-5
1, 3-Piehlorobmaau
,�xx^^ tin
uq/1
1.1
1.0
1.0/29/01
PPM
541-73-1
1,4-OSShl.orobeaxeae
)m
xg/1
1.10
1.0
10/29/01
PRE
106-66-7
1,2•D2.eb1orobeuxeae
MD
u9(1
1.0
1.0
1.0/29/al
PPM
95.50.1.
1 •C'hlhm-3-ElmtabPaunae
D2
4
3.0
10/29/01
PPN
625.99.9
^1&'r
-y8�1A5'�Q
Y+HI II/OB/Of.
W C I..�d"�
Po9ei t
).yhgl�il, T-ULEi(1,4yon INe
REPORT OF LABORATORY ANALYSIS
�6nmlary fxrtH'ratlan IOc
Water 90090
NO Wastewater ,z
Rv orinkft
NC prinking Water 37703
This report shall p01 be reproduced meept in NII,
VA prinking Water 219
SC gg000
without the written consent at Pace Analytical Services, Inc.
FI. NELAP FM27

r-)
00870 P.003/003
aceAnalytical"
wwn.parnlasrmm
pass Analytical serv(sss, Inc.
99p9p7nxyAveaue, s61M Im
H010118s.NC28078
Phone: [phone]
Rr.704876.9091
Lab project dumber: P227104
Clieph, pxoject t0! RA9E/9324416
Lab sample 9w 931022364 nmjoct Sample Numbsr.: 02271.36-h02 Gate Cellectedt 10/21/01 00,00
Clieat eemple Sp: BASE TRAM DL Matrix: alecer late ReCelved: 10/23/01 12:05
11ax" AarR 8ut)te Units_ M,eert Mai DkluhiaM Avai yzea CAS xQ._ Ppmp&e BSg List
GC volabilem
Volatile 0 1bd&.b4Ap by 601 Pxap/M0thod: MPA 601 / SPA 601
Cb1oYPlosm YG my/1 La 1.0 10/29/01 2104 PPM 67-SG-3
1;-CElem'3-tlucrabed%eaC `I(9) ab t 1.0 10/20/01 21r24 PPM 925-99.9
4iR��
w�
P.t., nhl j.
NO Waashmalawater 12 EDlrjg911RgJR6 REPORT OF LABORATORY ANALYSIS
NC W
NC Drinking Water 27708 This report shall not be reprodiing. oacept In full,
6C 09D09 wilhoutthe written consent of Pace Anatallcol Services, Ins.
ayrt i
tab0ratory-Dnrtititatian
IDa
KY Drinking Water
90a9a
VA Drinking Water
213
fl-NELAP
E87627

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
Division of Water Quality
0
110
ae
Af ti.�
NCDENR
NORTH CAROLINA DP TMENT OF
ENVIRONMENT ANO NAT.R, RESOURCES
WATER QUALITY SECTION
Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Dear Mr. Dellinger:
ti�r�a<�zatjl
Subject: Compliance Sampling Inspection
Status: In Compliance
BASF Corporation
Q Wastewater Treatment Facility
\ NPDES Permit Number NC0000299
uncombe County, North Carolina
-The --Compl-fiance Sampling -Inspection -that I -conducted oh -May 23,
2001, showed that the wastewater treatment facility for BASF
Corporation was in compliance with terms and conditions contained in
NPDES. Permit No. NC0000299. Operation and Maintenance (O&M) activities
continue to be performed in a satisfactory and effective manner. A copy
of the inspection report is attached for your review.
Should you have questions or wish to discuss this report in more
detail, please contact me; telephone [phone].
Your
Z ul
Max L. Haner
Environmental Chemist
Enclosure
CC: Maurice Horsey, EPA
Forrest R. Westall
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%mcycledi10%post-consumer paper

..,_..... NORTH .CAROLINA DEPARTMENTOF ENVIRONMENTAND.NATURAL RESOURCES. .__..
Division of Water Quality - Water Compliance Inspection Report (EPA Form 3560-3)
Section A: National Data System Coding
transaction NPDES N Yrl.olday inspection type inspector facility type days facility self monitorin evaluation rarm
New NC0000299 00/05/23 CSI State (2) 1 3 (lv.unreliable/3 satisfactory/5v.reliable)
Section 8: Facility Dan
Name and Location of Facility
BASF CORPORATION
US HWY 19/23 @ NC HWY 112
ENKA, N.C.
-BUNCOMBE COUNTY
Entry Time:
0830HRS
Permit Effective:
95/12/01
Exit Time:
1125HRS
Permit
Expiration:
2000/09130"
Name(s) of On -Site Representative(s) Title(s) Phone number(s): Fax number(s):
RAY ACKERMAN ORC 828- 667-7277
KAY CROWDER
Name, Title, Address of Responsible Official:
JACK A. DELLINGER
BASF CORPORATION
ENKA, NC 28728
Phone number(s): 828-667-7110
Fax number(s): 828-
Contacted? No
Section Cc Are. Evaluated During inspection is - Satisfactory, M - Marginal, U - Unsatisfactory, N - Not Evaluated
5 Permit S Flow Measurement 5 Operations & Maintenance N Sewer Overflow
5 Records/Reports S Self -monitoring Program N Sludge Handling/Disposal N Pollution Prevention
S Facility Site Review N Compliance Schedules N Pretreatment N Multimedia
S Effluent/Receiving Waters N Laboratory N Storm Water N Other:
Section D* Surnmary of Findings/CommentskCampliance Status tAttach additional sheets f
EFFILLUENT DATA ICOMPOSITE SAMPLESI EFFLUENT LIMITS (MO AVE / DAILY MAM PERMIT TO NOTICE 5/23101 -
FLOW = Q.478 MGD 1.25 MGD
ISS
.. OOML
TRC x.
-
19 C NOT LIMITED
ZINC Q.1s #1DAY 38 UG/L 6.35 #/DAY / 643.5'UG/L
THE WWTP WAS IN FULL OPERATION. WIYH ALL UNITS APPEARING IN GOOD WORKING ORDER. BOTH CLARIFIERS SHOWED SOLIDS IN
THE EFFLUENT LAUNDER.
THE ORC ADVISED THAT THE CHLORINE CONTACT CHAMBER 15 CHECKED REGULARLY FOR SOLID
ACCUMULATION WITH
REMOVAL AS NEEDED. TH€SYSTEM OPERATION IS BASED ON MLVSSWHICH ROUTINELY RUNS BETWEEN 1000 TO
1300 MG/L. CURRENT
MLVSS LEVEL REPORTED AT-:1000 MGIL. SAMPLING EQUIPMENT, FLOW MEASUREMENT & RECORDING UNITS,
APPEARED WELL MAINTAINED, PM PROGRAM EFFECTIVE. VEGATATION IN FINAL BASIN SHOULD BE REMOVED. COMPLIANCE NOTED
Compliance Status: X Compliance Marginal Compliance/Deficiency Non -Compliance
Name(s) and 5ignatur (s) of lnspe tor(s)/reiephone: Agency/Office: Date: 6/26/00
MAX L. ANER
828-251-6208 Water Quality Section Asheville Region
Name and gna of Re e F rr t I
Fax: [phone]
Da
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10%post-consumer paper

Qo
�
e
x
x
y
9-
C
pp
x

/
§
!
_
222\\2\^!g
;b//\aess,a
�
.
.
SSe,
G\2Ed

_
�I!
\0
u
i
|

Sale of Conductive Fibers Unit
Forwarded by Raymond L Ackerman/KFF/ENKA/BASF-CORP/BASF
on 01/29/2001 08:39 AM
Raymond L Ackerman
O1/23/2001 08:57 AM
To: max.haner
CC:
Subject: Sale of Conductive Fibers Unit
Max,
On January 9, 2001 BASF sold the Conductive Fiber Unit at Enka to Shakespeare
Corporation. The sales will not impact the operation our WWTP nor does it make
any change pursuit to the requirements our NPDES Permit. We will continue to
treat the 5 to 8 gallons per day of waste water that comes from this unit under
our service agreement with Shakespeare.
If you have any questions or concerns, I can be reached at 667-7277 or by e-mail
at ackermrobasf.com
Regards,
Ray
1 of] 10/4/2001 8:07 AM

Re Sale of Conductive Fibers Unit
To: Raymond L Ackerman <[e-mail]>
CC: Tom Belnick <[e-mail]>, Forrest Westall <[e-mail]>,
Max Haner <[e-mail]>
Reply
Ray - Thanks for the report of BASF's sale of its Conductive Fiber Unit to
Shakespeare Corporation. This notice constitutes compliance with Reporting
Requirements contained in Part I1 Section E of the permit even though there doesn't
appear to be any change in the waste characteristics or volume. I understand that
BASF will continue to accept and treat the wastewater from this process as part of a
service contract. I am placing a hard copy of this notice in your file for
reference and am forwarding this e-mail to Tom Belnick of our NPDES Permits Unit so
that this information can be added to your renewal application. Please advise if
there are additional changes. Max
> Raymond L Ackerman
> 01/23/2001 08:57 AM
> To: max.haner
> cc:
> Subject: Sale of Conductive Fibers Unit
> Max,
> On January 9, 2001 BASF sold the Conductive Fiber Unit at Enka to Shakespeare
> Corporation. The sales will not impact the operation our WWTP nor does it make
> any change pursuit to the requirements our NPDES Permit. We will continue to
> treat the 5 to 8 gallons per day of waste water that comes from this unit under
> our service agreement with Shakespeare.
>
> If you have any questions or concerns, I can be reached at 667-7277 or by e-mail
> at [e-mail]
Regards,
> Ray
Max Haner - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Max Haner <Max.Haner&ncmail net>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
1 o1`2 JOW2001 8:08 AM

r
y
a
E
i
n
S
F
i
Y
3
f
I

a NORTH. CAROLINA DEPARTM NT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
April 17, 2000
Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Subject Performance Audit Inspection
Inspection Rating 'IC"
Wastewater Treatment Program
BASF Corporation
NPDES Permit Number NC0000299
\Bu combe County, North Carolina
Dear Mr. Dellinger:
The Performance Audit Inspection (PAI) that Gary
Francies and I conducted an March 23, 2000, of BASF's
wastewater treatment program resulted in an overall rating
of MC" relative to the evaluation of sampling, flow
measurement, and laboratory procedures. Regulatory and
methodology violations were identified in the laboratory
oortion of the inspection which centered again (see previous
inspection report of 2/18/99) around sample handling,
analysis, or data reporting procedures for fecal coliform,
total suspended residue and BOD. Ammonia procedures were
also cited. Comparison of results of split sample analysis
between the BASF laboratory and the NCDENR Water Quality
laboratory was favorable as was data transfer.
The results of this PAI should not be interpreted to
question compliance with terms and conditions contained in
the NPDES permit. Sample analysis showed the discharge to be
meeting effluent limitations and the evaluation of the
wastewater treatment facility showed proper operation and
control.
INTERCHANGE SUR.O'H-, SB WOOOFIN GLACE. ASHEVILLE, NORTH CAROUNA 28801-2414
ORON0628-251-8208 FAX [phone]R2
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 509e REcvcLE O/10% POST-CONSUMCR PAPER
�aea�tSlflxesa3�SaP"a+,i&3tY�M,

Page 2
April IV, 2000
Mr. Dellinger
A copy of the report is attached for your review. I£ you have
questions regarding this report, please do not hesitate. to contact
Mr. Francies or me at [phone]
Yo truly,
Haner
E ironment al Chemist
Enclosure
cc: Melinda Greene, EPA
Forrest R. Westall
Gary. Francies

United States En( )mental Protection Agency
Form Approved
Washington, D.C. 20460
OMB No. 204M003
EPA NPDES Compliance Inspection Report
Approval Expires 7-31-85
Section A: National Data System Coding
Transaction Code NPDES yr/mwday Inspection Type Inspector Fee Type
1 IN 1 215 1 3 1 NC0000299 11 12 00/03/23 17 16 19 IS1 20u
u LJ u LJ
Remarks
Reserved Facility Evaluation Rating BI QA Reserved
67 I 169 70 ''i 71 I N on72 N u73 I I 174 75 � 80
I I u I
Section B: Facility Date
Name and Location of Facility Inspected ..
Entry Time
Permit Effective Date
BASF CORPORATION
0900 HRS
95/12/01
US HWY 19/23 & NC 112
Exit Time/Date
Permit Expiration Date
ENKA, INC, BUNCOMBE COUNTY
1600 HISS
00/09/30
Names) of On -Site Representativeds)/Fitle(s)
Phone Nods)
RAY C. ACKERMAN, ORC
[phone]
MANAGER, ENVIRONMENTAL/SAFETY/QUALITY
Name, Address of Responsible Official
Title
JACK A. DELLINGER
GENERAL MANAGER
BASF CORPORATION
Phone No.
Contacted
ENKA, N.C. 28728
[phone]
NO
Section C: Areas Evaluated During Inspection CODES v S - Satisfactory M - Marginal U - Unsatisfactory N - Not evaluated(Not applicable
$
Permit
Records/Repwtx
Facility Site Review
$
Flow Measurement
Laboratory
EHluent/Receiving Waters
N
Pretreatment
Compliance Schedules
Self -Monitoring Program
$
Operations &Maintenance
Sludge Disposal
Other:
$
$
N
S
S
$
$
Section On Summary of FindingOCommente (Attach additional sheets it necessary)
EFFLUENT DATA ( (COMPOSITE) PERMIT LIMITS (MO AVE/ DAILY MAXI
FLOW — 0.606 MGD 1.25 MGD
SOD, 5-DAY — 71 #/DAY (14 MG/q 136 #/DAY / 291 #/DAY
TSS = 91 #/DAY T8MG/U 209 #/DAY / 565 #/DAY
FECAL COLIFORM = NS /100ML (GRAB) 20W100MU 400/100ML
D.O. = 9.4 MG/L ® 14-C NOT LIMITED
PH 7.80 (BASF) 6.0 / 9.0 (RANGE)
RCL — 0.14 NOT LIMITED
THE W WFP WAS IN FULL OPERATION. WITH ALL UNITS APPEARING IN GOOD WORKING ORDER.. ONE OF THE TWO CLARIFIERS (SOUTH CLARIFIER)
WAS OUT OF SERVICE FOR ROUTINE CLEANING, THE FINAL POLISHING BASIN CONTAINED A HEAVY VEGATATIVE GROWTH (ALGAE) WHICH
COULD CAUSE COMPLIANCE PROBLEM IF ALLOWED TO FURTHER DEVELOP. RECOMMEND THAT BASIN BE CLEANED OF ALGAE GROWTH AS NEEDED.
THE DISCHARGE WAS IN COMPLIANCE WITH PERMIT LIMITS.
Nani and Signatures) Ins ctor(s)
Agency/Office/Felephone
Date
MAX L. HANER
DWQ/ARO 828-251-6208
(�jtN
Signora fewer
Agency/Office
Date
DWQ/ARO 828-251-6208
Regulatory Office Use Only
Action Taken
Date
Compliance Status
D Noncompliance
Compliance

r)
PERFORMANCE AUDIT INSPECTION
WASTEWATER TREATMENT FACILITY (NC0000299)
BASF CORPORATION
ENKA, NORTH'CAROLINA
MARCH, 2000
INTRODUCTION
On Thursday, March 23, 2000,,.the North Carolina Division of Water
Quality conducted an on -site inspection of BASF's wastewater
treatment program including evaluation of the laboratory and
sample collection procedures.
The Performance Audit Work with the Company's laboratory, sample
collection and flow measurement procedures were conducted by Gary
Francies and Max Haner of the Division's Asheville Regional
Office. Personnel from BASF Fibers were Ray L. Ackerman, Manager,
Environmental/Safety/Quality and Operator in Responsible Charge
(ORC) of the wastewater treatment facility; Kay Crowder,
Maintenance Superintendent and backup operator; Carl Jackson &
Darrell Mills, electrician; Glen "Butch" Howell, contract
laboratory (PACE); and Eric Barbour, Utilities Superintendent.
The purpose of this inspection was to determine the quality of
the self -monitoring program being conducted by BASF Fibers
Corporation and assess the reliability of its reported data.
The inspection consisted of evaluation of the flow monitoring
equipment and data handling, evaluation of sample collection and
preservation techniques and evaluation of laboratory and -
analytical techniques, record keeping and data reporting
procedures. NPDES permit number NC0000299 provides for a
discharge (001) from the Company's wastewater treatment facility;
two equalization basins (series), an aeration basin, dual final
clarifiers, a chlorine contactchamber, a mixing lagoon, sludge
handling and disposal (thickener, conditioner, filter press, BASF
landfill as cover) with discharge to Hominy Creek, Class "C"
waters in the French Broad River Basin. Additionally, the permit
provides for a discharge (002) of non -contact cooling water from
a barometric condenser into Hominy Creek via the east ditch on
BASF property.
BASF Fibers Corporation is conducting the self -monitoring part of
this program in accordance with monitoring requirements contained
in NPDES Permit Number NC0000299. Flow measurement, composite
sampling and collection of samples is satisfactory. Violations
were found in the laboratory methodology part of the inspection
relating to procedures for Ammonia Nitrogen, TSS, Fecal Coliform,
and BOD.. Four (4) of these violations were cited in the previous
inspection report of February 18, 1999. As result the PAI rating

Page 2
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
for this inspection is "C", as opposed to the "B-Minus" rating
received during the previous inspection. The PAI rating sheet is
attached for your review. A "C" rating results from a finding of
several minor problems during the inspection. For this rating,
the general operation of the overall facility is noted as good.
FINDINGS AND RECOMMENDATIONS
Recommendations contained in this section are based either on
regulatory requirements or approved methodology. These
recommendations are intended to correct violations noted during
the inspection.
A. FIELD EVALUATION
FLOW MEASUREMENT: Flow is measured at the
discharge structure in the final mixing lagoon using a
30-inch cipolletti weir with a Miltronic ultrasonic
depth probe and Honeywell Recorder. The unit is
checked once per week for accuracy. It also is checked
for accuracy during zero flow periods when the level of
thefinal basin is lowered for maintenance. This
effluent flow measuring device and as well as the
calibration procedures that are being followed by BASF
personnel are evaluated annually by Law Engineering;
last report transmitted February 2, 2000. A check of
the weir showed it to be plumb, level, and meeting
requirements for a properly installed cipolletti weir.
Instantaneous flow measurement at the weir appeared to
show less than a 10% difference in comparison with the
recorded measurement.
a. RECORDS: Records are maintained in a hardbound
notebook by Carl Jackson and Darrell Mills,
maintenance (electrician).
b. DATA HANDLING: Flow totalizer measurements are
handling properly.
SAMPLING PROCEDURES: The effluent composite
sampling device for discharge 001 is an ISCO model
371OR unit with refrigeration. The permit requires no
monitoring of discharge 002.
Effluent 24 hours composite samples are collected
proportional to flow with a setting of 125 ml per
cycle. The sample aliquot measured 120 mi. The
sampling cycle occurs at 32 pulse intervals;
approximately 5,000 gallons.

Page 3
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
b. Pump and sample tubing replaced as necessary as
per preventative maintenance program. Basis for
replacement is routine volume measurement of
composite sample and physical appearance of tubing
The sample strainer is routinely checked as
cleaned (brushed) as necessary.
C. Records: Included in the records maintained for
this unit is��the volume of each composite sample,
when the pump and sample tubing is replaced, and
the temperature of each composite sample upon
collection.
3. FIELD MEASUREMENTS:
a. The effluent dissolved oxygen (D.O.) measurement
is measured daily during the time the composite
sample is collected for analysis using D.O.
.meter and probe. D.O. measurement of the
discharge was 9.4 mg/l @ 140 C (NCDWQ).
b. The effluent pH measurement is performed in the
laboratory from a grab sample collected from the
discharge during sample pickup. The pH was
measured at 7.8 s.u. (BASF).
C. The effluent total residual chlorine concentration
is measured in the laboratory from a grab sample
collected from the discharge. during sample pickup.
The total residual chlorine was measured at 0.14
mg/l. (NCDWQ).
4. SAMPLE HANDLING: The composite sample (carboy)
was properly handled with the sample being thoroughly
mixed prior to transfer to the sample container(s).
5. RECORD MAINTENANCE: Preventative maintenance
work performed on the system was in accordance with
needs addressed in the weekly computer printout.

Page 4
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
6. OPERATION & MAINTENANCE: O&M is being performed
in a satisfactory manner. The south clarifier had been
drained for routine maintenance. A condition of the
solids appearing sporadically in the clarifiers since
December, 1999, reportedly shows a characteristic of
being weighty and gelatinous; creating a torque
problem in these units. A determination of the cause of
this problem is underway. Wasting of solids is based on
F/M ratio and volatile solids in the system (target
1100-1200 mg/1). -
7. PERMIT VERIFICATION: The facility is operating
in compliance with terms and conditions contained in
the NPDES permit (NC0000299). The permit accurately
reflects the existing wastewater treatment facility and
discharge location.
B. LABORATORY EVALUATION
1. PERSONNELL: All NPDES testing performed at this
facility is under supervision of Ray Ackerman. The manager
of the laboratory is Jack Dellinger, PhD. Glen "Butch"
Howell, retired from BASF, performs laboratory analyses
as an employee of Pace Laboratories, Inc.
2. FACILITIES AND EQUIPMENT: The laboratory is
spacious and adequately equipped for testing performed at
this location of this facility. The laboratory routinely
conducts tests for pH, BOD, Total Suspended Residue, Fecal
Coliform, Ammonia, Zinc, Total Residual Chlorine, and
Temperature. The BASF laboratory is state certified for the
above parameters. Pace Laboratories, Inc., performs the
remaining NPDES analyses including Aquatic Toxicity.
METHODOLOGY: All testing procedures are based upon
the Laboratory Certification Regulation; 15A NCAC
2H.0800, or approved methodology. Violations are
entered as follows:
a. Violation —Ammonia
The value obtained for the laboratory control
standard was not always calculated and documented.
Regulatory Requirement: Supporting records shall
be maintained as evidence that these practices are
being carried out effectively. All analytical
records must be maintained and available for a
period of three years. 15A NCAC 2H .0805 (a)(7) &
(7) (G) .

Page 5
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
b. Violation - Ammonia
The percent deviation from the standard curve for
5 of 62 samples was outside the recommended 10%
variance and the problem was not evaluated and
resolved.
Regulatory Requirement: Whenever a laboratory
control standard is outside the recommended 10%
variance, the analysis is out of control and must
be terminated until the problem is corrected.
15A NCAC 2H :0805 (a)(7)(B)&(F) and Approved
Methodology: Standard Methods, 18`h Edition,
Method 1020 3.3.
C. Violation - Fecal Coliform
Regarding sample preservation, dechlorination of
the fecal coliform sample was not properly
documented and therefore is considered as not
being performed. This violation was cited in the
previous inspection (2/18/99).
Regulatory Requirement: Samples containing
chlorine must be dechlorinated at the time of
sample collection and treated according to the
requirements of the analysis to be performed. Upon
receipt in the laboratory, samples treated for
chlorine must be checked and documented to be free
of chlorine. 15A NCAC 2H.0805(a)(1)&(7)(M)&(N)
d. Violation - Fecal Coliform
The autoclave log must provide a record to show
when the temperature gauge is used and when this
gauge is checked against the maximum holding
thermometer.
Approved Methodology: Standard Methods, 18th
Edition, Method 9020 B.2i The operating
temperature of the autoclave must be verified at
least once per week by checking it against the
maximum holding thermometer.
e. Violation - Total Suspended Residue
The time that the sample is placed in the oven for
drying and the time that the sample is removed
from the oven was not being documented. This
violation was cited in the previous inspection
(2/18/99).
Regulatory Requirement: The drying times must be
documented unless every sample is reheated and
redried to a constant weight. 15A NCAC
2H.0805 (a) (7) &(a) (7) (D)

Page 6
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
f. Violation - 130D
The seed correction factor must be in the range of
0.6 mg/l to 1.0 mg/l. Records indicate the seed
correction factor for this analysis was outside of
this range. This violation was cited in the
previous inspection (2/18/99).
Approved Methodology: Standard Methods, 18th
Edition, Method 5210 B.4d 2.
Regulatory Requirement: Any time that control test
results indicate an analytical problem, the
problem must be resolved and any samples involved
in the test must be reanalyzed if the holding time
has not expired. 15A NCAC 2H .0805 (a)(7)(F).
g. Violation - BOD
The SOD value obtained for 23 of the last 38
glucose-glutamic acid standard sets was outside
of the acceptable control range (167.5 mg/l to
228.5 mg/1) and the resulting data were not
qualified.
Regulatory Requirement: Any time that control test
results indicate an analytical problem, the
problem must be resolved and any samples involved
in the test must be reanalyzed if the holding time
has not expired. 15A NCAC 2H .0805 (a)(7)(F) and
Approved Methodology: Standard Methods, 18'
Edition, method 5210 B.6a.
h. Violation - BOD
Data reported on the discharge monitoring report
(dmr) are not qualified on the dmr form when
quality control requirements are not met. This
violation was cited in the previous inspection
(2/18/99).
Regulatory Requirements: iSANCAC 2B 0506 (a)(1);
15A NCAC 2B.0506 (b)(3)(J); and Part II, Section
D, Monitoring and Records, Number 7 of NPDES
Permit Number NC0000299 require that all effluent
sample data be reported on certified monthly
report forms. 15A NCAC 2H.0805(a)(7)&(a)(7)(D)
requires that sample data reported but not meeting
quality control requirements must be noted on the
discharge monitoring report.

C"3
Page 7
2000 PAI Report
BASF Corporation Wastewater Treatment Facility
4. RECORDS KEEPING:
Laboratory record keeping was consistent with good
laboratory practice. Records were complete and well
detailed.
5. QUALITY CONTROL:
Effluent samples split with the BASF laboratory showed
the following comparison:
BASF LABORATORY DWQ LABORATORY
SODS 11.4 mg/l 13.5 mg/l
TSS 19 mg/l 18 mg/1
FECAL COLI 284/100 ml 215/100 ml*
*Non -effluent - comparative purposes only
6. DATA HANDLING & REPORTING:
A review of discharge monitoring report (dmr) and
supporting data for September & November, 1999 and
January, 2000, showed no data entry or dmr transfer
problems. The facility was transcribing data in a
satisfactory manner.

PAI RATING SCALE
Rating General Descri tion
A The facility has no problems with flow monitoring,
sampling, analyses or data calculating and reporting
procedures. The overall self -monitoring program and
the quality and reliability of the data reported to
state/federal agencies are excellent. The general
operation of the entire facility is also very. good.
The facility has a few minor problems in one or more
areas of flow monitoring, sampling, analyses or data
calculating and reporting procedures. Examples include
infrequent calibration of flow monitoring equipment,
improper refrigeration of samples, slight discrepancies
in oven or incubator temperatures and not keeping
thorough records. The self -monitoring program is good
and the problems have no major impact on data
reliability. The overall operation of the facility is
very good.
The facility has a major or several minor problems with
flow monitoring, sampling, analyses or data calculating
and reporting procedures. Examples include
malfunctioning flow monitoring equipment, improper
sampling site, not dechlorinating fecal coliform samples,
unacceptable oxygen depletions and improper seed
correction factors in BOn analyses. The problems noted
at the facility cause the reliability of some of the data
to be questionable. The general operation of the overall
facility is good.
There are major problems withflow monitoring, sampling
analyses or data calculating and reporting procedures.
Examples include estimating flow, collecting samples at
wrong locations, using improper glassware or equipment,
malfunctioning laboratory equipment, poor laboratory
techniques, or errors in data calculations. The problems
cause the reliability of the self -monitoring data to be
highly questionable. The overall operation of the
facility is fair.
Severe problems with flow monitoring, sampling, analyses
or data calculating and reporting procedures cause the
self -monitoring data to be unreliable. Examples include
no flow monitoring capabilities, wrong sampling
frequencics and procedures, using unacceptable analytical
techniques or fabrication of information. The self -
monitoring program and the general operation of the
facility is poor.

LAW
LAWG" iBB Group fliernberAIAL
January 24, 2001
Mr. Kay Crowder
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Subject: Wastewater Treatment System Effluent Discharge Weir Calibration Confirmation
BASF Corporation
Enka, North Carolina
LAW Project 30300-1-0893
Dear Mr. Crowder:
Law Engineering and Environmental Services, Inc. (LAW) is pleased to submit this report of our
assessment of the effluent flow measuring device used at yew Enka facility. The purpose of ow
services, as described in the attached report, was to observe the method of flow measurement and
equipment calibration for the wastewater treatment system discharge weir. Based on our
observations and calculations, the calibration method used by BASF appears to be complete and
accurate.
We appreciate the opportunity to provide our professional services on this project. Please contact
us at [phone] if any questions arise or if we may be of further service.
Sincerely,
LAW ENGINEERING AND ENVIRONMENTAL SERVICES, INC
p'V`wvlu'V V• WV1X�^�`�
/�/{�jy��((1(, Vl.lc-IJ=U.I.P
Matthew E. Wallace, P.E.
l/J. David Wallace, P.E. bpq n;
BY
Senior Engineer
Principal Water Resources Engineer
WITH PERMISSION
Registered, NC #24933
Registered, NC #20055
MEW/JDW:mew
attachment
LAW Engineering and Environmental Services, Inc.
1308-C Patton Avenue
Asheville, NC 28806
828-252-8130 • Fax [phone]

�� �)
BASF Corporation -Report oj. stewaier Treatment System Discharge January 14, 2001
Weir Calibration Confirmation
LA W Project 30300-1-0893
Background Information
The BASF Enka facility processes raw materials used in the production of synthetic fibers. The
facility operates its own biological wastewater treatment system located on the property. The
wastewater treatment system is used to condition the process and domestic wastewater generated
at the facility to an acceptable level to allow for discharge to the environment. After treatment, the
wastewater is discharged into a creek that flows through the BASF property. Approximately
500,000 to 600,000 gallons of process water are treated and discharged each day from the facility.
A weir has been installed at the wastewater effluent discharge point to monitor the volume of fluid
that is discharged. The current weir has been in place for approximately seven years. As a
condition of the discharge permit, the flow -measuring device is required to be calibrated on a
regular schedule. BASF personnel have developed and are following a prescribed calibration
procedure. BASF has requested that LAW review their calibration procedure, and certify that the
procedure is complete and accurate.
Site Observations
On January 18, 2001, LAW representative Matthew E. Wallace visited the BASF Enka site to
inspect the head/flow measuring and recording equipment used and to observe the head measuring
and calibration procedures. BASF representative Cart Jackson conducted a tour of the equipment
and explained, step-by-step, the calibration procedure. Following is a discussibn of the equipment
observed and a description of the calibration procedure.
BASF uses a trapezoidal (Cipolletti) weir as the effluent flow -measuring device. The weir is
attached to a concrete wall that restricts and channels the effluent flow through the weir. The weir
is constructed of what appears to be a stainless steel plate, and is approximately one -quarter of an
inch thick. The weir plate is bolted to the concrete wall and is sealed around the perimeter to
prevent flow of water around the plate. The upstream edge of the weir crest is smooth and
perpendicular to the flow of fluid. The downstream section of the weir is chamfered. The crest
length of the weir is 30 inches long. The weir is level and perpendicular to the channel in both the
horizontal and vertical dimensions. A trapezoidal weir has angled sides at both ends of the weir
crest. The BASF weir crest is recessed approximately 15 inches below the top of the plate. The
11

BASF Corporation -Report o1 sharater Treatment System Discharge J January 24, 2001
Weir Calibration Confirmation
LAU Prouct 30300-1-0893
angled sides above the weir crest are sloped outward at a slope of 1 unit horizontal to 4 units
vertical. Therefore the horizontal distance between the tops of the angled sides is approximately
37.5 inches (see Figure 1). The weir appeared to be free of excessive build up of debris.
The flow of water into the weir was not turbulent and was ventilated over the crest of the weir.
The cross -sectional area of the approach channel is at least eight times that of the nappe of the
weir at the crest for a distance upstream of greater than 20 times the head on the crest. Also, the
height of the weir from the bottom of the channel is greater than two times the maximum expected
head of liquid above the weir crest. It appears that the weir is positioned at an elevation sufficient
to prevent the downstream liquid level elevation from rising above the crest of the weir during
normal operation. The liquid head measuring device (Milltronics Multiranger Plus -Ultrasonic
level gauge) is positioned upstream at a distance greater than three times the maximum expected
head on the weir, in quiescent section of the channel. Based on these observations, the weir is
constructed in such a fashion that flow measurements should be reliable.
Calibration Procedure
To establish equipment accuracy, at a frequency of approximately once every two weeks, the
continuous ultrasonic flow -measuring device is calibrated against a manual check by BASF. A
wastewater treatment system operator measures the height of water over the weir, calculates the
flow of water expected at the measured head and compares the results with'the flows generated
from the continuous reading automated system. The operator first cleans the upstream face of the
weir with a scrub brush to remove any accumulated debris that may contribute to measurement
error. Next the operator takes a two -foot long jig, one end of which he places on the weir crest and
orients the jig parallel to the flow direction. A level attached to the jig is used to level the jig and a
depth of water reading is taken at the upstream end of the jig, which is positioned two feet behind
the weir crest. The depth of water upstream from the weir crest can be determined to within an
accuracy of one -sixteenth of an inch. The operator also measures the output from the ultrasonic
level gauge. The ultrasonic level gauge is calibrated to measure head depths upstream from the
weir crest from zero to eight inches with a corresponding output of 4 to 20 milli -amps (with 4
milli -amps corresponding to zero inches of head). The gauge also has a LCD display of liquid
head level in feet. The accuracy of the zero reading of the ultrasonic level gauge was evaluated by

BASF Cmporation-Report 0�stewaterT Treatment System Discharge J January 14, 2001
Weir Calibration Confirmation
LdW Project 30300-1-0893
lowering the water level in the discharge channel. The water level in the discharge channel was
pumped down and the LCD display output for the ultrasonic level gauge was observed. As the
water level decreased, so did the LCD output. After the water level was lowered approximately
one-half inch below the crest of the weir, operation of the discharge pumps was terminated. The
LCD output was observed as the water level recovered in the discharge channel. The operator has
calibration tables for determining discharge flow rates based on head height over the weir and
ultrasonic liquid level gauge outputs. At the time just before the flow of water over the weir
resumed (within two seconds), the LCD display was fluctuating at 0.000 feet within a range of
0.007 feet (attributable to minor surface water waves), and the milli -amp output was 4.06. The
variance of 0.06 milli -amps represents a positive flow error of approximately eight gpm, based on
the transmitter calibration chart. A copy of the calibration tables has been attached.
At the time of our observations, the measured height of liquid over the weir was 2-5/16 inches.
During normal operation, the output from the Milltronics instrument is sent to the wastewater
treatment control room, where the signal is converted and physically recorded on a 24-hour
circular paper chart. The chart is multi -channel and records both the effluent weir flow in gallons
per minute (gpm) and the pH of the liquid. In addition to the circular chart flow rate display, there
is a liquid crystal display of the instantaneous discharge flow rate. The effluent flow rate value
recorded on the circular chart and the corresponding instantaneous: flow rate observed on the
digital readout at the time of the manual measurement was 336 gain. A Fluke hand-held meter
was used to measure milli -amp output from the Milltronics instrument. Ayceading of 6.84 milli -
amps was measured, and the corresponding control panel flow reading was 340 gpm.
Conclusions
The flow rate determined by the Milltronics instrumentation and taken from the strip chart
recorder with digital display was 336 gam. The flow rate calculated from the manual water level
reading at the weir (2-5/16 inches) using the calibration chart was 324 gam. .The flow rate
calculated from the manual water level reading at the weir (2-5/16 inches) was 320 gpm using the
discharge (head vs. flow rate) equation of a free flowing Cipolletti weir, as presented below:
3

BASF Corporation -Report astewafer Reatment SJsteni Discharge nl January 24, 2001
Weir Ca/iboozes Confirmation
LAW Reject 30300-1-0893
Q=1511*L*H1.5
where: Q = Flow rate (gpm)
L = Crest length of the weir (feet)
H = Head on the weir (feet)
The measured electronic reading of 6.84 milli -amps corresponds to a flow of 370 gpm, utilizing
the transmitter calibration charts. The flow reading at the control panel at the time of the
electronic reading was 340 gpm. This difference in calculated flow based on the field milli -amp
reading and the displayed control room reading can be largely attributed to accuracy in the hand-
held electronic measuring device used at the transmitter panel in the field. LAW recommends the
continued practice of recording flow rate based on the converted reading of the flow meter in the
control room.
The flow rate at the time of the calibration was calculated from the weir equation to be 320 gpm.
The error between the flow rates from the control panel reading (i.e., 336 gpm) and calculated -
from the weir equation using the manual measurement (i.e., 320 gpm) is approximately 4.9
percent. The error between the flow rates from the head reading utilizing the calibration charts
(i.e., 324 gpm) and calculated from the weir equation using the manual measurement (i.e., 320
gpm) is approximately 1.2 percent.
It should be noted that the weir is oversized for the normal discharge flows. Based on information
received from BASF, the normal discharge flow rates from the BASF Enka facility fluctuate from
a low of around 250 gpm to a maximum of 650 gpm. The normal range of flows usually ranges
from 350 to 400 gpm. To handle flow rates of 250 to 400 gpm, the crest length of the weir needed
is only 1.5 feet long. The minimum suggested flow rate over a 2.5-foot wide crest length weir (as
installed at the BASF Enka facility) is 338 gpm. With average discharge flow rates ranging from
approximately 350 to 400 gpm the weir is operating at or below the minimum suggested flow rate.
However, the error introduced by using the current weir should be relatively negligible. It appears
that the calibration method used by BASF is proper and correct.
4

QyZ'l. Cove
�J
MM WASTEWATER. TREATMENT
PLANT .
FINAL EFFLUENT DISCHARGE
AT COVE
2.5 FT WIDE CIPOLLETTI WEIR
CALC
HEAD
FLOW
SIGNAL
IN
MGD
ma
0
0.0000
4.00
1
0.1309
4.70
2
. 0.3702
5.97
3
0.6801
7.63
4
1.0470
9.58
5
1.4633
11,80-• - -
6
1.9235
14.26
7
2.4239
16.93
8
2.9615
19.79
MAX
MAX
MAX MAX
HEAD
HEAD
FLAW FLAW
FT
IN
MGD GPM
0.672
8.0640
2.9911 2081.21
5/24/I
TRANSMITTER CALIBRATION - 3'HGl
MGD - 0.6463 * 8.419 * H expl.5
CALC
APPROX
SIGNAL
FLAW
HEAD
ma
MGD
IN
4
0.0000
0
4.5
0.0938
13/16
5
0.1675
1
1/4
5.5
0.2813
1
11/16
6
0.3750
2
6.5
0.4688
2
5/16
17
0.5625
2.5/8
7.5
0.6563
2.15/16
8
0.7500
3
3/16
8.5
0.8438
3
7/16
9
0.9375
3
11/16
9.5
1.0312'
3
15/16
10
1.1230
4
3/16
10.5
1.2188
4
7/16
11
1.3125
4
5/8
ll.5
1:4063
4
718
12
1.5000
5
1/16•
12.5
1.3938
'S
5116
13
1.6875
5
1/2
13.5
1.7813
5
21/16
14
1.8750
5
7/8
14.5
1.9698
6
1/16
15
2:0625
6
5/16
15.5
2.1563
6
1/2
36
2.2500
6
12/16
16.5
2.3438
6
13/16
17
2.4375
7
17.5
2:5313
7
3/16
18
2:6Z30
7
3/8
18.5
2.7188
7
9/16
19
2.8225
7
3/4
19.5
2.9063
7
7/8
20
3.0000
8
1/16

r7gure 3
SHARP CRESTEDM� ,m
K - A;Pmr. 116 hn
k—►
P91n1 to
k
meecure Draxdawn
kaea
or
— Neppe
ventilation
r; : u _. 1 nr5 1:
CFS: -Q-3.367LH1s
MOD: Q = 2.176 L H1'S
GPM; Q = 1511 L H"
Q = flow mte
H = Head on the weir
L - Crest length of weir in ft.
4 : k-`M 1,s
4V
1
O.II
0.701'
0.105.
1J5:
0.5
1.19
0.789
581
11h
0.2
0.462
0.292
203
0.75
3.28
2.17
1470
2
02
0.502
Man
_ 270.-%,..J.0
8.73
.125
,70N
21h
02
0.753
0.121
$33
125
11.3
7.90
3300
7
U.
0.903
0.584,
405;,,,,
.,1.5
122
.120
8050
4
02
1.20
0.270
539
20
38.1
24A
17.100
5
02
j.6±
0,M
.._ 478, a_
. 25
OU ,
.40.0
, 20,100
6
0,2
1.81
1.17
112
3.0
105
67.9
47,100
1
02
2.41
1.58
,1080 ,
4.0
114
138
88,000
t0
0.2
-3.01
1.95
1350
5.0
375
243
166,000

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
Division of Water Quality
NCDENR
NORTH CAROLINA v11
Ervvigory nerves N.THIa .. Resourzces
WATER QUALITY SECTION
Mr. Ray Ackerman
Environmental Manager
BASF Corporation - Enka Site
1451 Sand Hill Road
Enka, North Carolina 28728
Dear Mr. Ackerman:
March 28, 2001
Subject: NOTICE OF VIOLATION
Effluent Limitations
BASF Corporation
QtNPDES Permit Number NC0000299
Buncombe County
Review of subject self -monitoring report for the month of January,
2001, revealed violation(s) of the following parameter(s):
Pipe Parameter
001 00530.RES/TSS
Pipe/Date Parameter
001/01-02-2001 00530 RES/TSS
001/01-04-2001 00530RES/TSS
Reported
Value/Unit
240.0 LB/DAY
Reported
Value/unit
575.0 LB/DAY
627.0 LB/DAY
Monthly Ave Limits
Value/Type/Unit
209.0 FIN LB/DAY
Daily Maximum Limits
Value/Type/Unit
565.0 FIN LB/DAY
565.0 FIN LB/DAY
Remedial actions, if not already implemented, should be taken to
correct the above compliance problem(s). Please understand that the
Division of Water Quality may pursue enforcement actions for this and any
additional violations of State Law. If you have questions or if you need
assistance, do not hesitate to call Mr. Max L. Haner at [phone].
Sincerely,
rrestlReta l�
Water Quality Regional Supervisor
xc: Max L. Baser
59 Wnndfin Plnce, Asheville Nnrlh Cm'olina 28801 lde plmne 828-251;6208 FAX [phone]
An Egnnl Oppod.oily ARrmelive Acllnn Engnoyer 50%recyded/10% pdslmnnsumer pdper

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place Asheville, North Carolina 28801
December 21, 2000
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Mr. Ray Ackerman
BASF Corporation -. Enka
1451 Sand Hill Road
Enka, North Carolina 28728
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0000299
BASF Corporation WWTP
Buncombe County
Dear Mr. Ackerman:
This is to inform you that a review of your toxicity self -monitoring report form for the month of October
2000 indicates a 'violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent
toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (TRE) which is a
site -specific study designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity,
evaluate the effectiveness of toxicity control options, and then confirm reductions in effluent toxicity. Please be
aware that North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES
permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note updated mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this
information and if it would be helpful to discuss this situation or possible solutions to resolve effluent toxicity
noncompliance, please contact Mr. Keith Haynes with this office at [phone].
Sincerel ,
Porrest Westall %—" —
Regional Water Quality Supervisor
cc: Keith Haynes -Asheville Regional Office
Aquatic Toxicology Unit
Central Files

WHOLE EFFLUEN'1'TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following Items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information, please take time to review this information. ng Rceirs 6 1 do net address
include' all the t 't ilytesting and Mn ding req i nits contained in4ourNpues Q_ k. If you should have any
questions about your toxicity testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at
[phone] or another Unit representative nt the same number.
➢ The ep rmittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data Is a dual requirement. All toxicity test results must be entered (with
the appropriate parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity tot meillis shall be filed with the Environmental S ' Branch no later than 30 d4yo afterthe d of th
t;oortrhg period (eg, January test result is due by the end of February).
D Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity
testing upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower
than the permit limit, then at least two multiple concentration toxicity tests (one per month) will be conducted over the
following two months. As many analysesas can be completed will be accepted. if your NPDFS permit does not require
use of multiple concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either
single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement
initiatives effective Judy 1, 1999. Follow-up multiple concentration toxicity testing will Influence the Division's
enforcement response. _
D Toxicity testing months are specified by the NPDFS Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements leg, if the testing months specified in your NPDFS permit are March, June, September, and
December, then toxicity testing must be conducted during these months).
➢ If your NPDFS Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not
occur during the first six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should Immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
Invalidated and the date when follow-up testing will occur.
D If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete
the information block located at the top of the AT form indicating the facility name, permit number, pipe number, county
and the month/year of the subject report. You should also write "No Flow" on the AT form, sign the form and submit
following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except for
facilities which have not escriced a facility classification. In these cases, a duly authorized facility representative must
sign the AT form. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality, you may consideryou may consider submitt n
your toxicity test results certified mail return receipt requested to the Environmental Sciences Branch.

Penick tccm sl nppfu.d.. - NC0000299
Subject: permit renewal application - NC0000299
Date: Too, 16 May 2000 14:11:47 -0400
From: Charles Weaver <chaxles.weaveeQncmaiLnet>
To: arkermx@basfcom
Mr. Ackerman, the NPDES Unit received the renewal application for your
permit on April 3, 2000. Thanks for submitting this package in a timely
fashion. I'm sorry that I didn't respond to your request sooner. I
(along with the other 9 members of our Unit) spent the last several
weeks working on a large project in the Neuse Rivet basic, a project
that included 2 public hearings on May 1st and May 4th. This "maximum
effort" was accomplished at the expense of all our other tasks -
uxluding the checking in of permit mnewsls.
The NPDES Unit has been working with at least 3 (and as many as 5)
vacant positions since October 1998. This staff shortage is delaying
all of our permit renewals. Our remaining staff are currently reviewing
Authorizations to Construct, speculative limit requests, major permit
modificatims before working on Fount
renewals. This is necessary due to a variety of factors, including
mandatory deadlines in the statutes which govern our program.
If this staff shortage delays reissuance of NC0000299, the existing ,
requirements in that permit will remain in effect until the permit is co
renewed (or other action is taken by the Division). We appreciate your
patience and understanding as we operate with a severely depleted staff.
If you have any questions about your pemnt (or the permit renewal
Process in general), simply reply to this a -mail.
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
1 of 1 5/16/00 2:12 pM

BASF Corporation n
BASF
March 27, 2000
Mr. Charles H. Weaver
NC DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Request for Renewal of NPDES Permit NC0000299
Dear Mr. Weaver:
I am requesting renewal of our NPDES Permit # NC0000299 per your request dated
February 10, 2000.
Also, as requested, the following changes have taken place with our facility since our
last renewal in 1995:
The most significant change in the operation of our WWTP has been a major reduction
in both hydraulic and BOD load to our system since 1995. Through waste minimization
efforts, mainly in our Polymerization Plant, the flow to our WWTP has been reduced from
over 0.8 MGD to approximately 0.5 MGD. The organic load has also been reduced due
to these efforts from over 600 mg/1 BOD to around 400. This has been done while
increasing the capacity of the Polymerization Plant from 70 Million pounds per year to
approximately 110 million pounds per year.
Regarding changes in equipment or operating procedures, the WWTP is virtually
unchanged. Some change in aeration capacity has been affected by replacing rotor type
aerators with subsurface aerators.
There has also been a decline in sanitary waste during this time as the site has some
370 fewer employees.
The permit application requested the submission of Priority Pollutant Analyses, a Form A
submission was mailed to Central Files in Raleigh on March 23. 2000.
1 have authorized Ray Ackerman to prepare this application. If you have questions,
please contact Ray at [phone].
Sincerely,
J ctl k Deng
General Manager, Enka Site
UVV
Sand HIII Road. P.O. Box 669. Enka, North Carolina 28728-0669 [phone]

NPDECApplication Form - Standard(]rm C
Major Manufacturing or Commercial Facilities
SECTION II. BASIC DISCHARGE DESCRIPTION
this section for each discharge from the facility to surface waters.
All values for an existing discharge should be representalrve of the Twelve previous months of operetion. II This is a proposed tlischarge, values an
reflect best engineering estimates.
t. Outfall Number 001 and Type Process and sanitary wastewater
Give the nature of the discharge (process water, non -contact cooling water, etc.)
2. Discharge To End Date: 12/31/00
If the discharge is scheduled to be discontinued within the next 5 years, give the date (or best estimate) the discharge will end.
3. Discharge Receiving Stream Name: Hominy Creek
Give the name of the waterway (at the point of discharge) by which it is usually designated on published maps of the area. lithe discharge is to
an unnamed tributary, so state and give the name of the first body of water fed by that tributary which is named an the map, e.g., UT to McIntire
Creek, where McIntire Creek is the first water way that is named on the map and is reached by the discharge.
4. Discharge Type and Occurrence
a. Check whether the discharge is continuous or intermittent. If the discharge is intermittent, describe the frequency of discharge
D Continuous n Intermittent
b. Enter the average number of days per week (during periods of discharge) this discharge occurs.
7 days per week
5. Water Treatment Additives
Complete the table below if this ou tall;
• discharges cooling anclor steam water generation
• water treatment additives are used (any conditioner, inhibitor, or algiclao)
• does not have whole -effluent toxicity testing required
Additive
Manufacturer
Quantity
(pounds added per million
gallons of water treated(
Chemical Composition
(active ingredieni
2 of

NPDOApplication Form - Standarnrm C
Major Manufacturing or Commercial Facilities
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
16,17 Mail Service Center, Raleigh, NC 27699-1617
SECTION 1. APPLICATION AND FACILITY DESCRIPTION
Unless otherwise specified on this ions all dems are to be completed Iran item is nor imputable indeale'NA'.
1. Applicant and facility producing discharge
This applies to the person, agency, fin,municipality, or any other entity that owns or is responsible for the permitted facility. This may or may not
be the same name as the facility or activity producing the discharge. Enter the name of the applicant as it is officially or legally referred to; do not
use colloquial names as a substitute for the official name.
Name BASF Corporation — Fiber Products Division
Mailing address of applicant:
Street address 1451 Sand Hill Road
City Enka County Buncombe
State NC Zip Code 28728
Telephone Number ( 828 ) 667-7277 Fax Number ( 828 ) 667-6969
e-mail address [e-mail]
2. Mailing address of applicant's Authorized Agent / Representative:
Complete this section if an outside consulting fimd engineering finn will act on behalf of the applicant / permittee
Street
- State
Zip Code
Telephone Number ( )
Fax Number
e-mail address
3. Facility Location:
Street address 1451 Sand Hill Road
City Enka Cnl Into Buncombe
State NC - Zip Code 28728
Telephone Number ( 828 ) 667-7277 Fax Number ( 828 ) 667-6969
4. Nature of Business: Manufacturer of nylon 6 polymer and industrial fibers
State the nature of the business conducted at the plant or operating facility
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such
information is true, complete, and accurate.
Sack A. Dellinger General Manager
ended Name of Person signing mle
Nolh card'ma General suf 143 21561b1121 crowded that Any portion who name, makes any false statemenl reambeholion, or oedification In any apple tenon raamo reparl, plan, another
tlaument tiles or requires tohementamed under Arddr,21 or egulahow d the Ermimnmertal Management Commission Implemen4ng Nat Ankle, or who trades, tampers,am or knowingly
renders lnaacurale any recording or monitoring device ormotion required lobe operated or amounted under Adde 21 or regulations of the Erwidunmental Management counterman lmptemttrling
Thal Anide,sballbeguillyolamisdemeanorpunishablabyalNendtoeviceed Sm,Wd, or by amid naonmoral not to errand tip months, or by both (1a US.C. Sadion lWl damdes A punlahmenl by
a fine or more than Stands or Imprisonment not more than 5yeam, or both, fora similar offense)
1 of

N]l �)NppHcation Form - Standard(-)rm C
Major Manufacturing or Commercial Facilities
SECTION 11. BASIC DISCHARGE DESCRIPTION
Complete this section for each discharge from the facility to surface waters.
All values for an existing discharge should be representative of the twelve previous months of operation. It this is a proposed discharge, values sh
reflect best engineering estimates.
1. Outfall Number Got and Type Non -contact: cooling water
Give the nature of the discharge (process water, non -contact cooling water, etc.)
2. Discharge To End Date: N/A
It the discharge is scheduled to be discontinued within the next 5 years, give the dale (or best estimate) the discharge will and
3. Discharge Receiving Stream Name: Hominy Creek
Give the name of the waterway (at the point of discharge) by which it is usually designated on published maps of the area. II the tlischarge is to
an unnamed tnbutary, so state and give the name of the first body of water fed by that tributary which is named on the map, e.g., UT to McIntire
Creek, where McIntire Creek is the first water way that is named on the map and is reached by the discharge.
4. Discharge Type and Occurrence
a. Check whether the discharge is continuous or intermident. If the discharge is intennidenl, describe the frequency of discharge
® Continuous 0 Intendant Frequency:
b. Enter the average number of days per week (during pandas of discharge) this discharge occurs.
7 days per week
5. Water Treatment Additives
Complete the table below it this oudall:
• discharges cooling and/or steam water generation
• water treatment additives are used Jerry conditioner, inhibitor, or algicide)
O does not have whole -effluent toxicity testing required
5EA-
204

NPDC!Application Form - Standard'-'�rm C
Major Manufacturing or Commercial Facilities
OUTFALL NUMBER 001
6. Wastewater Characteristics
Check the box beside each constituent present in the effluent (discharge water),
This determination is to be based on actual analytical data or best estimate (for proposed discharges).
Parameter
Present
Parameter
Present
Color
00080
Copper
01042
Ammonia
00610
Iron
01045
Organic nitrogen
00605
l�
Lead
01051
Nitrate
00620
Magnesium
00g27
Nitrite
00615
Manganese
01055
Phosphorus
00665
✓
Mercury
71900
Sulfate
00945
Molybdenum
01062
Sulfide
00745
Nickel
01067
Sulfite
00740
Selenium
01147
Bromide
71870
Silver
01077
Chloride
00940
Potassium
00937
Cyanide
00720
Sodium
00929
Fluoride
00951
V
Thallium
01059
Aluminum
01105
Tftanmm
01152
Antimony
01097
Tinacompounds*
Arsenic
01002
Zinc
Beryllium
01012
Algicides'
Barium
01007
Chlorinated orga52Boron
01022
Pesticides'
Cadmium
01027
Oil and grease
00550
Calcium
00916
Phenols
32730
Cobalt
01037
Surfactants
38260
Chromium
01034
Chloride
50060
Fecal coliform
74055
Radioactivity
74050
3 of

NPDEApplication Form — Standard-Irm C
Major Manufacturing or Commercial Facilities
7. Supplemental Documentation
Submit the following information appended at the end of this application form. All sheets should be approximately letter size with
margins suitable for filing and binding. All pages should include facility location and permit number (if available).
❑ Present Operating Status: Provide a narrative description of installed wastewater treatment components
at the facility. Include sizes & capacities for each component.
❑ Potential Facility Changes: Provide a narrative description of any planned upgrades / expansions /
repairs planned for the facility during the next five years. Do not include tasks associated with routine
operation & maintenance.
❑ Schematic of wastewater flow: Provide a line drawing of water flow through the facility. The schematic
should show flow volumes at all points in the treatment process. Specific treatment components should
be identified.
❑ Location map: Submit a map showing the location of each outfall. The usual meridian arrow showing
north as well as the map scale must be shown. On all maps of rivers, the direction of the current is to be
indicted by an arrow. All outfalls should be identified with the outfall numbers) used in Section II of this
application. A copy of the relevant portion of a USGS topographic map is preferred.
❑ Production Data: Submit the last 3 years' production data for the facility. Where applicable, use units
specified in the appropriate subpart of 40 CFR.
❑ Priority Pollutant Analysis: Industrial facilities classified as Primary Industries (see Appendix A to Title 40
of the Code of Federal Regulations, Part 122) must submit a Priority Pollutant Analysis (PPA) in
accordance with 40 CFR Part 122.21. If the PPA is not completed within one week of the due date for
the permit application, submit the application package without the PPA. Submit the PPA as soon as
possible after it is completed.
4oi4

NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
Sludge Management Plan
The Enka Site Waste Water Treatment Plant is an activated sludge process designed to
handle 1.25 million gallons per day of industrial and domestic waste water. The plant now
operates at a nominal 0.5 millions gallons per day during the peak summer months.
Due to the large capacity of the aeration tank (2.0 million gallons) the plant operates in
the extended aeration mode with a sludge age of 30+ day.
Sludge is wasted continuously from the two 40 foot clarifiers operated in parallel. The
sludge is pumped to a 20,000 gallon thickner at approximately 20-40 gpm where it is
settled and pumped to a 0.5 million gallon aerobic digester with a detention time of
approximately 50 days.
The digested sludge is coagulated with polymer and pumped to a plate and frame filter
press where it is dewatered using diatomaceous earth as a precoat.
The resulting sludge cake is applied to the Enka Site Landfill as a soil conditioner for the
final cover for slope closures,
Approximately 2,600 Ibs of sludge are disposed of daily to the landfill
A ec- L'k-12u.._
R. L. Ackerman
Environmental Manager

NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
Present Operating Status
The Enka Site Waste Water Treatment Plant is an activated sludge process designed to
handle 1.25 million gallons per day of industrial and domestic waste water. The plant now
operates at a nominal 0.5 millions gallons per day during the peak summer months.
Due to the large capacity of the aeration tank (2.0 million gallons) the plant operates in
the extended aeration mode with a sludge age of 30+ day.
The plant is comprises of the following components listed in order from influent to effluent:
Waste water components:
Equalization Basin No. 1 —1.75 MG clay -lined mixing basin.
Equalization Basin No. 2 — 0.5 MG metal tank for adding nutrients and pH control.
Aeration Basin - 2.0 MG concrete basin with 350 Hp of aeration capacity.
Clarifiers — two each 40 ft. diameter, 90,000 gallons capacity
Chlorine contact chamber— baffled 20' X 40' concrete basin
Sludge Handling Equipment:
Sludge thickner— 20,000 gallon tank
Aerobic digester— 0.5 MG steel tank with concrete bottom and
Plate and Frame filter press for de -watering sludge — 2 each with 13 cubic ft capacity

NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
Potential Facility Changes
Plan are currently being formulated to close the Enka Site Waste Water Treatment Plant
and discharge our waste water to Metropolitan Sewerage District of Buncombe County
North Carolina. The target date for closure of the W WTP is December 31, 2000.

I.'
h1_13r 1
Enka
Lake
—l•aoao��. A✓�.
ELEV 20E9' -
1
r
'JSCS 7-1/2
MINUTE
SER= MAPS
iu
i
ENKA,
NCR 7.n
CARGLINA
EK%2
=
T^_PCGRAPH;C
�UADRANGL-
ENSR CONSULTING AND ENGINEERING
I
=
FIGURE 1
SITE LOCATION MAP
SCALE
BASF Corpo-Von
Enter, Monn Germano
1000 D
1000
2000
ADDD
DRAWN'.
KLR
OAiL
2/29/00
PROJECT NUMBER
RCV
e
0760-047-502
100001 A4

NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
Production Data for Past Three Years
Polycaprolactam (Nylon Chip)
Conductive Fibers
Basofil® (Fire retardant fiber)
1997 1998 1999
(In 1,OOO pounds)
81,268 76,912 76,757
550 550 528
242 330 638

BASF- Enka Facility; NC0000299
FromTlrtn 90%ick <toih 6Kek@hpntail net'3-
SPbC btJ$7 ¢P HnkaFgo'Wify NO299
To: Max Haner <[e-mail]>
Hello Max- I talked with Dave Goodrich and he wants to keep this permit
moving, given pressures from EPA about backlog. I proposed to draft the
permit with no substantive changes, and give a permit expiration date of
May 31, 2002. This should cover them through the anticipated WWTP
closure by end of 2001, with some leeway in case construction problems
arise. I ran this by Ray Ackerman and he's o.k. with it. I told him we
could modify the permit to delete Outfall 002 requirements once they
secure General Permit coverage. Do you see any problems with this?
Mailto:tom.belnickuncmail.net
N.0 DENR-DWQ/NPDES Unit
1617 Mail Service Center, Raleigh NC 27699-1617
Work: [phone] ext. 543
Fax: [phone]
I ON 3/12/2001 4:50 PM

15'2000 14:99 82B 667 7778 SITE AOMIN 00299 P.001/003
BASF Corporation � r)
Facsimile Cover Sheet
To: Max Haner From: Ray Ackerman
BASF Corporation
Sand lilll Road
Enka, NC 28728
Fax: [phone] Phone;
Phone: Fax:
Date: 9/15/00
Pages; 3
Subject; Letter Sent to Enka Village Residents
cc;
Comments:
For your information.
Ray
v%

15'2000 14:99 928 667 7778 SITE ADMIN 40299 P.002/003
BASF Corporation �B�F
September 15, 2000
To residents and property owners of the Enka Village and businesses:
This letter is being sent to you on behalf of BASF Corporation to explain
anticipated changes that will affect sewage treatment services for residents and
other users in the Enka Village. BASF Is in the process of evaluating alternatives
to on -site treatment of its own wastewater. These alternatives will mean a
change for all users of the current system.
By way of background, American Enka Corporation began treating Enka Village
sewage in 1966, In that year, American Enka Corporation agreed with Enka
Park Commission (then representing the Village residents and properly owners),
to allow sewage from the residences and other buildings in Enka Village to be
treated through American Enka's plant wastewater treatment system. BASF
Corporation became owner of the Enka site in 1966 and has continued the free
sewage treatment service for the past 14 years.
The treatment of the Enka Village sewage had been intended as a temporary,
Interim measure. As part. of the 1966 agreement between American Enka
Corporation and Enka Park Commission, the parties agreed that six (6) months'
prior written notice to tite Commission would be given before discontinuing
service. Upon the giving of that notice, service could he discontinued on March
15th in any calendar year after 1967,
In addition to this letter, a public notice terminating the 1966 agreement is being
Published in the September 1 sth issue of the Asheville Citizen -Times newspaper.
According to the 1066 Agreement, the notice was to be given to the commission.
However, to try to reach all affected persons In the Village, the newspaper public
notice is also addressed to residents and property owners.
The Commission and the residents and property owners in Enka Village will need
to have an alternate service in piece no earlier than March 15, 2001 because
service may be discontinued on that date.
BASF will cooperate with the Commission and the residents and property owners
to facilitate a smooth transition. BASF has met with the local Metropolitan Sewer
District (MS©) to discuss the situation. The plan is to work with MSp and the
residents and building owners to develop and implement an allernative for
sewage treatment for the Village. If the transition time extends beyond March 15,
2001, BASF is willing to consider changing the actual date for service
discontinuation to a reasonable time beyond March 15, 2001,
vwk U144 _
S4md 1W F.ed, P.e. a-x 659, Enka, N�Hh 01-11ha 28729.0111 [phone]

15'2000 14:99'020 667 777E SITE ADMIN #0299 P.003/003
September 15, 2000
Page 2
Plans are very preliminary at this paint and are being developed with MSD.
BASF has discussed with MSD scheduling a series of public meetings M provide
detailed information about: the planned transition to connect to the MSD system.
Also, community leaders are being contacted to develop a resource network to
be involved in the planning and to provide Information to the residents.
It is anticipated that before the end of October 2000, additional information will be
available about the public meetings and a plan of action for the transition.
No additional information is available at this time. Therefore, please do not call
BASF directly upon receipt of this letter. No one at the BASF Enka location will
be able to give you more Information than is contained in this letter. As plans
develop, BASF and MSD will convey the information to the Village residents and
building owners through the resource network being formed.
BASF is committed to working with the residents and building owners of Enka
Village, Its community leaders and the MSD to make this transition a smooth one.
Sincerely,
BASF Corporation

Cooling Water Discharge
January 12, 2001
Proposal:
Our proposal is to remove the cooling water discharges from the plant wastewater
treatment system and permit them under a General Permit allowing them to be discharged
directly to Hominy Creek. This would require separate permits for BASF and Colbond.
Present Situation:
Reference: Attachment A-- Sketch of cooling water discharge.
The existing non -contact cooling water process streams now combine with the
site's sanitary streams. This flow then is processed through our wastewater treatment
plant before being discharged to Hominy Creek. Some streams (#2 and #10 on
Attachment A) are part of the Plant's current NPDES permitted outfall 002 which
discharges via our east ditch to Hominy Creek,
Proposed Conditions:
Plans are being made to curtail the operation of the plant's wastewater treatment
facility and discharge wastewater to MSD. With this change, modifications to the input
streams are being completed. These modifications include the following: separation of
discharges from the Enka Village and the A-B Tech properties from BASF waste streams,
and the discharging of the sanitary sewers and process waste streams to MSD. MSD has
requested that we not discharge our cooling water steams to their facility.
To make this change, the plant's systems will have to be modified. We will use the
monitoring point of our existing permitted 002 outfall and add several additional
monitoring points. These additional monitoring points are necessary because of the
distance between locations. The monitoring points are designated by letters A through E
on Attachment A. We would request that the flow for the combined streams #1, #2, and
93 be determined by subtracting the flow of point A from that of point B.
Colbond would have one primary point designated as letter A and BASF would have
points B through E. The weir for the discharge point C will be new construction.

Biocide additions are made to streams designated as 1, 4, 5, 6 for BASF and 11 and 12 for
Colbond.
Biocides utilized:
Points 1 and 4 use Drew Chemical No 2155 cooling water treatment.
Point 5 uses Nalco StaBrEX
Point 6 uses Nalco 7346 TAB
Point 11 and 12 use Garratt-Callahan No 312 and No 315 with 2002 Rust Inhibitor
The water source for the process activity is from the site's process water system with the
exception of streams no 10 (raw water) and no 11 (city water).

7
COOLING WATER DISCHARGE
ATTACHMENT A
COLBOND
t0,000 GPD
E%TRUDER
COOLING
7,500 GPD
M-3 DRYER
COOLING
12,000 GPD
CB DRYER
COOLING
RAW WATER
95,000 GPD
pET DRYER
COOLING
CITY WATER
AIR COMP
5,000 GPD
BIOCIDE--
COOLING
5,000 GPD
BIOCIDE - - ��HVAC
BIOCIDE--i►
SYSTEM
r,
cer6.w;
M4.w. pt
245 AOOO
GOD
0 V WEST STORM SEWER
L relay yo ctkv/�'—
\ 6y yevr a-4
i!
1 50
GPD O
REFRIGERATION . -BIOCIDE
COOLING
TOWERS
r
O 50 00 POLYMERIZATION
RIZATION
D COLUMN
CONDENSERS
COOLING
O 9eppODO ANTISTAT
EXTRUDER
S CHIP DRYER
COOLING
/ I \
BIOCIDE
75O
ZATION 6PD
TOWER
0
U
75
PD° 0 r---BIOCIDE
r i
POWERHOUSE
SPRAY POND
O 0 r i I BIOCIDE
o3oao004.025
REV D

Re: Sale of Conductive Fibers Unit
it4;oph, ax .'0' axu'fIn6'�"Qn©)natil:net> , c 'x m,
M `10 1�,�.ttbirod'�sihers Unit
To: Raymond L Ackerman <[e-mail]>
CC: Tom Belnick <[e-mail]>, Forrest Westall <[e-mail]>,
Max Harter <[e-mail]>
Reply
Ray - Thanks for the report of HASPS sale of its Conductive Fiber Unit to
Shakespeare Corporation. This notice constitutes compliance with Reporting
Requirements contained in Part II Section E of the permit even though there doesn't.
appear to be any change in the waste characteristics or volume. I understand that
BASF will continue to accept and treat the wastewater from this process as part of a
service contract. I am placing a hard copy of this notice in your file for
reference and am forwarding this e-mail to Tom Belnick of our NPDES Permits Unit so
that this information can be added to your renewal application. Please advise if
there are additional changes. Max
> Raymond L Ackerman
> 01/23/2001 08:59 AM
> To: max.haner
> cc:
> Subject: Sale of Conductive Fibers Unit
> Max,
On January 9, 2001 BASF sold the Conductive Fiber Unit at Enka to Shakespeare
> Corporation. The sales will not impact the operation our WWTP nor does it make
> any change pursuit to the requirements our NPDES Permit. We will continue to
> treat the 5 to 8 gallons per day of waste water that comes from this unit under
> our service agreement with Shakespeare.
> If you haveany questions or concerns, I can be reached at 669-9299 or by e-mail
> at [e-mail]
> Regards,
> Ray
Max Saner - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional office
Division of water Quality - Water Quality Section
59 Wcodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Max Haner <M m_ Hurernncmail.net>
NC DENR - Asheville Regional Office
Division of Water QualrtyyWater Quality Section
1 of2 1/29/2001 2:21 PM

SAS,.F r oration
G�
3 �
January 18, 2001 D �4• `16"2'''
!1 JAN 22 2001
Mr. James W. Meyer DkJV°Q
Laboratory Section LABORATORY SECTION
NC DENR
1623 Mail Service Center
Raleigh, NC 27699 -1623
Re: DMRQA20
Dear Mr. Meyer,
We received two "Not Acceptable" ratings on the referenced DMRQA study for our lab
(USEPA Lab Code # NC00030). However, since we have closed our lab effective
December 31, 2000, 1 am assuming no further action is required by me. My guess is that
closing the lab would constitute the ultimate "corrective action" to a deficient laboratory.
I have enclosed a copy of my letter dated December 26. 2000 informing you of our lab
closure.
If further action is required by me, I can be reached at [phone] or by e-mail of
[e-mail].
Sincerely,
a'
RAckerman
Lab Manager
Sand Hill Road, P.O. Box 689, Enka, North Carolina 28728-0669 [phone]

.ate of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
Division of Water Quality
WATER QUALITY SECTION
Ms. Lynn Davis
Asheville Savings Bank
it Church Street
Asheville, N.C. 28801
Subject:
Dear Ms. Davis:
October 26, 2000
Sewer Service For
39 Orchard Street
Enka Village
Buncombe County
NCIDENR
NORT{ CARourvh DEPARTMENT of
ENVIRONMENT r1ND NlS11RAL RESOURCES
This letter will confirm that the wastewater treatment facility serving the. BASF Corporation in
Enka, N.C., is operating under current NPDES Permit Number NC0000299. This five year permit was
last issued by this Division on October 23, 1995, with an effective date of December 1, 1995. Renewal of
this permit currently is being processed.
Based on information available to this office, property located at 39 Orchard Street is being served
by this treatment facility. Records indicate that the facility currently is in compliance with regulations
administered by this Division.
Thank you for the opportunity to comment in this matter. Should you wish to discuss the Bent
Creek wastewater treatment facility in more detail, please advise.
Yours y
M L. 11' e 4W
Environmental Chemist
59 Woodfin Place, Asheville North Carolina 28801 Telephone [phone] FAX [phone].
An Equal Opportunity AtSrmafive Action Employer 50% recycledl101l, post -consumer paper

TO:
N. C. DEPARTMENT )F ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTION
^HEVILLE REGIONAL OFFICE
59 WOODFIN PLACE
WORTH CAROLINA 28801
'251-6452
FAX # :
FROM:
DATE: ,�
c;;�
# OF PAGES INCLUDING THIS COVER:
MESSAGE: If questions, please call 828/251-6..
n
d gyp. STATE
PHONE: 828/

If -so - S onfu wdza- he vu u.4�
�5o f ba Ce( l�Gz 6bq—
U`l A,(� .�
�a
t 00 -4:
.5��-
�� Az5 4W6

OCPSF Categorical SN
Subject: OCPSF Categorical SIU �� �•�
Date: Mon, 24 Jul 2000 14:11:41 -0400
From: Keyes McGee <[e-mail]>-
Organization: NC DENRDWQ
To: Max Haner <[e-mail]>
CC: Monty Payne <[e-mail]>
Max,
Thanks for your question concerning BASF Company as an OCPSF Categorical Significant Industrial
User. Dana Folley and Steve Antigone assisted me in interpreting 40 CFR 403.6.
The issue in 40 CFR 403.6 (e) (i) & (ii) (c) referring to NRDC v. Costle paragraph 8, concerns Fri (Dilution
Flow). FD is either (a), (b), or (c) in this statement. This section is about a combined wastestream, formed
from the combination of categorical Fi (influent flow) and non -categorical FD .
OCPSF Categorical SIUs shall meet the following: "Samples shall be collected and analyzed by the
POTW Staff independent of the industry for each Significant Industrial User:", "for organic compounds
limited in the Significant Industrial User Permits, a minimum of once each year." (reference 15A NCAC
2H .0908 (d) (2)).
Please call the Pretreatment Unit if you have further questions.
Keyes McGee
Environmental Engineer Trainee
Department of Environment and Natural Resources
Division of Water Quality
Pretreatment Unit
Telephone: [phone], Extension: 580
Facsimile: [phone]
1 of 1 7/25/2000 332 PM

Re: Sale of Conductive Fibers Unit
From: Maz Harter <Max [e-mail]> ` i' w"' o14'2t041 PM
$object: Rei Sale of Conductive K1 ppUmt
To: Raymond L Ackerman <[e-mail]>
CC: Tom Belniek <[e-mail]>, Forrest Westall <[e-mail]>,
Max Haner <[e-mail]>
Reply
Ray - Thanks for the report of BASF's sale of its Conductive Fiber Unit to
Shakespeare Corporation. This notice constitutes compliance with Reporting
Requirements contained in Part II Section E of the permit even though there doesn't
appear to be any change in the waste characteristics or volume. I understand that
BASF will continue to accept and treat the wastewater from this process as part of a
service contract. I am placing a hard copy of this notice in your file for
reference and am forwarding this e-mail to Tom Belnick of our NPDES Permits Unit so
that this information can be added to your renewal application. Please advise if
there are additional changes. Max
> Raymond L Ackerman
> 0112312001 08:57 AM
> To: max.haner
> cc:
> Subject: Sale of Conductive Fibers Unit
> Max,
>
On January 9, 2001 BASF sold the Conductive Fiber Unit at Enka to Shakespeare
> Corporation. The sales will not impact the operation our WWTP nor does it make
> any change pursuit to the requirements our NPDES Permit. We will continue to
> treat the 5 to 8 gallons per day of waste water that comes from this unit under
> our service agreement with Shakespeare.
> if you have any questions or concerns, I can be reached at 667-7277 or by e-mail
> at [e-mail]
>
> Regards,
> Ray
Max Harter - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
F
axHarter<Max Haner(c�nemad.net>
DENR- Asheville Regvision of Water Quality -Water Quality Section
I oft 1/31/2001 8:23 AM

BASF Corporation
wQBASF
December26, 2000
!llSSSSSS DEC 28 20CD
Mr. James W. Meyer
Laboratory Section
DVVQ
LABORATORY SECTION
DENR
16
1623 Mail Service Center
Raleigh, NC 27699 -1623
Dear Mr. Meyer,
This letter is to confirm our telephone conversation of November 23, 2000 concerning
our certified Pollution Abatement Laboratory, As I stated to you then, our Laboratory,
USEPA Lab Code # NC0003O, will be shut down permanently on December 31 s` of this
year and all of our permit required testing will be done by Pace Analytical, Inc of
Asheville.
If you have any question concerning this action. I can be reached at [phone] or
by e-mail at [e-mail].
Sincerely,
R Ackerman
Lab Manager
Send HIII R08d, PA. Box 669, Enke, Narth Carolina 28728.0669 [phone]

corporation (1 BASF
July 27, 2000
Mr. Max Harter
Water Quality Section
NC Department of Natural Resources
59 Woodfin Place
Asheville, NC 28801
Dear Mr. Haner:
On July 25, 2000 we experienced an unanticipated bypass to our waste
treatment plant. Following are the details of the event and the planned activities
to prevent a recurrence:
On July 24th at 19:34, there was an interruption of power to the pumps at the #3
lift station that handles waste from our polymerization area and sanitary waste
from several restrooms on the east side of the plant. The cause of the outage
was a short in an underground electrical line encased in conduit. This power loss
caused the #3 lift station to overflow into the east ditch and go directly into
Hominy Creek. Given that it would take about four hours for the lift station sump
and adjoining distribution system to fill up before overflowing, we estimate that
the lift station began overflowing at around 11:30 p.m. on the 24th and continued
until 08:30 a.m. on the 25th, when repairs were made and the pump was
restarted. Pumper trucks were called in immediately to pump out the lift station in
order to diagnose the problem.
The nominal flow rate on that lift station is approximately 55 gallons per minute.
This would give a total loss to the east ditch of about 29,000 gallons of waste
water. The BOD load contained in this overflow is estimated to be around 1200
pounds. This estimate is based upon the loss of TOC in our plant influent as
compared to the average incoming concentration of TOC and our correlation of
TOC to BOD.
There has been a temporary line installed to supply power and maintenance is
preparing a project to replace the underground line with a new above ground line.
This is the only recorded incident of this kind ever occurring with any of our lift
stations; however, to prevent a recurrence the lift station is being supplied with
primary power from CP&L and backup power from our powerhouse.
Sand HIII Road, P.O. Box 869, Enka, North Carolina 28728-0669 [phone]

1 � l
Also to allow for earlier detection, an alarm system is being installed that will
send a signal to a control room that is manned 24 hours a day, 7 days a week
should there ever be another pump failure.
In compliance with House Bill 1160 and the Clean Water Act of 1999, BASF
issued a press release to the print and electronic media in Buncombe County on
July 27, 2000. A "Notice of Discharge of Untreated Sewage' will be submitted to
the Asheville Citizen Times during the week of July 31" in order to make the ten-
day deadline.
A "Sewage Spill Response Evaluation" is attached.
I can be reached at 667-7277 if you require additional information
Sincerely,
6y`Ac�k'erman
Environmental Manager
BASF Enka Site

Smafte Spill Ragonse Evaluation:
(page 1 of 2)
Penmktee AARF enrp..xarrnn Permit Numbwr N.nr nno2av County R,mrnmho
Incident Ended: (Date/Time L7 25/00 / 08:30 Esdinite i Duradon (Time) 9 hours
First knowledge of incident (DekO/lirM) 7/25/00 l 07:30
Estimated volume of spill/bypeiw 29,700 geNtxe. Show rational for volume.
55 gals./min. x 9 hrs. x 60 min./hr. = 29,700 gals.
ff spill Is crigWnp please nail Rgow l Office on a dolly basis until ap/N can be stopped.
Reported to: Max Raney _~raw) 7/25/00 / 16:00
Name of person .
Weather conditions: Heavy rain
Source of spill/bypass (check one): _Senhery Sewer X Pump Station W WTP
Level of treatment (check one): x None _Primary Treatment
Secondary Treatment _ Chlorination Only
Did spill/bypass reach surface Welars? __Z_Ya _No (If Yea, please list Mey hollowing)
Volume reaching surface waters? 29.700 gallons,.„e+,�_L
Name of surface water Hominy CreekJUL 3 1
wl ;
Did spilUbypass result in a fish kllY/ T,Ya x_No a
If Yes, what is the estimated number M MII kWad? 4V41 7 QI7411'I 6 IUY
Please provide the followinginflminwitlon:
1. Location ofsplll/bypaae: No. 3 lift station at (lead end of east ditch
2. Cause of spillbypeae: Power line to pump shorted out
3. Did you have personnel "lobls to pubrmfiilYl assaftiment 24 hourslday (Including weekends and
holidays)?
Yes _.Z _ No_
a. How long did R take to make on initial assessment of the apllgovsNow deer first knowledge?
't Hours 30 Minute
How long did R take to get a repair am slpks?
0 Hours 0 MRtataa - on site
Please explain the time taken to male inNW aosm mart Pumyer trucks ersummoned
Immediately and arrived at 08:30. It took until 11:00 to evawecuate lift
tar' hpfnre cause was determined.
Revisionel 6/11/99

Sewage Spill Response Evaluation:
(paea s of z)
Permitlee BASF Corporation ppmh Nurfdlar NC0000299 County Buncombe
5. Action takento contain. spill, clean up wash, on"ir rarrtadbta the atte:
6. Were the equipment and parts needed to make repairs readily aVailable7
Yes x No „ It no, pies" explain why:
7. If the spill/overflow occurred at a pump station, or was the result of a pump station failure,
was the alarm system functional at the dme of pro spill? Yee _ No 2 if the alarm
system did not function, please explain Why: • The high level alarms did not
function due to the power outage.
S. Repairs made are: Permanent _ Temporary X
Please describe what repairs were made. If the repairs are temporary, please indiate a date by
which permanent repairs will be completed, and notiry the Regional OPoa within 7 days of the
permanent repair. Temporary wire in place; permanent wire to be installed
creek of July 31.
9. What actions have been made to prevent this discharge ft en o= rring again in the future?
New power cableto replace old wires. An alarm to be installed to
indicate loss of power to pump in control room.
10.
unavoidable. _
Other agencies notifed: None
Person repbrtl epilbby s: Rip Ackerman photo Number(828) 667-7277
Signature t Dab: 7 - e—®d
For OM Use Only �M `
DWO requested additional written report? Yea No (r ,W,h1 C�
If yes, what additional Infomvtion is needed?
Requested by
Revision 01 6l11/99

,-)
State of North Carolina V
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place Asheville, North Carolina 28801
October 19, 2000
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Ray Ackerman
BASF Corporation Enka
1451 Sand Hill Road
Enka, North Carolina 28728
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0000299
BASF Corporation W WTP
Buncombe County
Dear Mr. Ackerman:
This is to inform you that a review of your toxicity self -monitoring report form for the month of August
2000 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent
toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (TRE) which is a
site -specific study designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity,
evaluate the effectiveness of toxicity control options, and then confirm reductions in effluent toxicity. Please be
aware that North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES
permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note updated mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this
information and if it would be helpful to discuss this situation or possible solutions to resolve effluent toxicity
noncompliance, please contact Mr. Keith Haynes with this office at [phone].
Sincerely,
Fortal�
Regional Water Quality Supervisor
cc: Keith Haynes -Asheville Regional Office
Aquatic Toxicology Unit
Central Files

_9:99 828 667 7778`.� SITE ANMIN j.� #0299 P.001/003
.3F Corporation
BASF
Facsimile Cover Sheet
To: Max Honer From: Roy Ackerman
BASF Corporation
Sand HIII Road
Enka, NC 28728
Fax: [phone] Phone:
Phone: Fax:
Date: 9l16/00
Pages: $
Subject: Letter Sent to Fnka Village Residents
cc:
Comments;
For your information.
Ray

/ \
.4:49 828 667 7778 1 SITE ADMIN
Corporation
September 15, 2000
"299 P.002/003
BASF
To residents and property owners of the Enka Village and businesses:
This letter is being sent to you on behalf of BASF Corporation to explain
anticipated changes that will affect sewage treatment services for residents and
other users in the Enka Village. BASF is in the process of evaluating alternative$
to on -site treatment of its own wastewater. These alternatives will mean a
change for all users of the current system,
By way of background, American Enka Corporation began treating Enka Village
sewage in 1966. In that year, American Enka Corporation agreed with Enka
Park Commission (then representing the Village residents and properly owners),
to allow sewage from the residences and other buildings in Enka Village to be
treated through American Enka's plant wastewater treatment system. BASF
Corporation became owner of the Enka site In 1986 and has continued the free
sewage treatment service for the past 14 years.
The treatment of the Enka Village sewage had been intended as a temporary,
interim measure. As part, of the 1066 agreement between American Enka
Corporation and Enka Park Commission, the parties agreed that six (8) months'
prior written notice to the Commission would be given before discontinuing
service. Upon the giving of that notice, service could be discontinued on March
16th in any calendar year after 1967.
In addition to this letter, a public notice terminating the 1966 agreement: is being
published in the September 15th Issue of the Asheville Citlaen4imes newspaper.
According to the 1966 Agreement, the notice was to be given to the Commission.
However, to try to reach all affected persons in the Village, the newspaper public
notice is also addressed to residents and property owners.
The Commission and the residents and property owners in Enka Village will need
to have an alternate service in place no earlier than March 15, 2001 because
service may be discontinued on that date.
BASF will cooperate with the Commission and the residents and property owners
to facilitate a smooth transition. BASF has met with the local Metropolitan Sewer
District (MSD) to discuss the situation. The plan is to work with MSD and the
residents and building owners to develop and implement an alternative for
sewage treatment for the Village. If the transition time extends beyond March 16,
2001. BASF Is willing to consider changing the actual date for service
discontinuation to a reasonable time beyond March 15, 2001,
S.W hIIIl Road, P.O. ace S6B, Enku, Nlrlh O»16Ma 28728-%59 [phone]

a4:44 828 667 777C 1 SITE ADMIN 1) #0299 P.003/003
September 15, 2000
Page 2
Plans are very preliminary at this point and are being developed with MSD.
BASF has discussed with MSD scheduling a series of public meetings to provide
detailed information spout the planned transition to connect to the MSD system.
Also, community leaders are being contacted to develop a resource network to
be Involved in the planning and to provide Information to the residents.
It is anticipated that before the end of October 2000, additional information will be
available about the public meetings and a plan of action for the transition.
No additional information is available at this time. Therefore, please do not call
BASF directly upon receipt of tills letter. No one at the BASF Enka location will
be able to give you more information than Is contained in this letter. As plans
develop, BASF and MSD will convey the information to the Village residents end
building owners through the resource network being formed.
BASF is committed to working with the residents and building owners of Enka
Village, Its community leaders and the MSD to make this transition a smooth one.
Sincerely,
BASF Corporation

/) N
-T^
A01 NORTH' )AROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
June 9,-2000-
Mr. R. L. Ackerman, Environmental Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Subject: Compliance. Biomonitoring Inspection
��. BASF - Enka Plant WWTP
NPDES Permit Number NC0000299
Buncombe County
Dear Mr. Mr. Ackerman:
Please find enclosed a copy of the Compliance
Inspection Report for the Biomonitoring Inspection which I
conducted at the subject facility on May 16, and 19, 2000.
The test result and measured water quality parameters
for these samples indicate that the effluent would not be
predicted to have water quality impacts on the receiving
stream. As noted in the attached Report, the test result
was recorded as a "Pass".
If you have any questions concerning the Report, or if
you require any assistance, please do not hesitate to
contact me at 251-6208.
Sincerely,,/ ,+
D. Keith Hayn
Environmental Specialist
Attachment
xc: Jimmie Overton
Max Haner
I NTePDXANOs em wlrvD, 5s WOOOPIN PLADE, A8MSVI11E, NO a88o 1-zala
HONER28-251-8208 FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST-CONSUM¢R PAPER

United States Erred, fend Protection Agency
Form Approved
Washington, D.C. ]0460
OMB No. 2040.0003
-
EPA NPDES Compliance Inspection Report
Approval Expires 7-31-85
Section A: National Data System Coding
Transaction Code NPDES, yonne/dey Inspection Type Inspector Far Type
I HIV 1_ _ 2[5 1 3 NC0000299 Ill 12 00/05/16 17 IS 19 20 �2
u u u
Remarks
Reserved Facility Evaluation Rating el CIA Reserved °
67 69 70 uI 71 oI 72L73 � 74 75 L�I ]_u80
Section B: FacilityData
Jame and Location of Facility Inspected
Entry Time
Permit Effective Date
IASF CORPORATION
9:50 am
95/12/01
JS HWY 19123 & NC HWY 112 (SAND HILL RD)
Exit Time/Date
Permit Expiation Date
INKA, NC (BUNCOMBE COUNTY)
11:00 am
00/09/30
James) of Ou-Site RepreWmative(sVfidee)
Phone Nob)
IAY C. ACKERMAN, ORC & MGR OF ENVIRONMENTAL SAFETY & QUALITY
[phone]
;AY CROWDER/DON CANIPE
Jame, Address of Responsible Official
Title
)R. JACK A DELLINGER
GENERAL MANAGER
IASF CORPORATION
Phone No.
Contacted
NKA, N.C. 28728
(828) 667 - 7110
No
selon C: Areas Evaluated During Inspection CODES w S - Satisfactory M - Marginal U - Unsatisfactory N - Not evaluatedlNot applicable
N
Permit
Records/Repods
Facility Site Review
N
Flow Measurement
Laboratory
Effluent'Remiving Waters
N
Probes to or
Compliance Schedules
Self -Monitoring Program
N
Operations & Maintenance
Sludge Disposal
Other. AQUATIC TOX
N
N
N
N
N
N ]
N
$
Section D: Summary of Findings/Commends (Attach additional sheets if necessary)
In May 17, 2000, Division Aquatic Toxicology personnel Initiated a 3-Brood Ceriodephnie dubla passifail toxicity test on the effluentfrom the subject W WTP.
he samples were collected on May 16 and 1&19, 2000 by Asheville Regional Office staff.
he result of the test indicated that the subject discharge met criteria set forth in established standards. Al the instream waste concentration of (IWC = 8.0%),
radiated by the low stream flow 7010 of 23.0 eta and the permitted discharge volume of 1.25 mgd, 91.7%survival occurred in the test population with an
verage of 22.6 neonates per lest organism. The control population exhibited 100 %survival with an average of 24.0 neonates per control organism. Thus, the
ud was recorded as a °Pass". Other measured water quality parameter results were: first sample, pH=6.06 SU, conductivity=1130 micromhoslcm, TRC=<0.1
1g/I; second sample pH=8.00 SU, conductivity=1060 micromhos/cm, TRC=<0.1 mgll.
lames) and SignaNrels) spectods)
Agency/Office/Telephone
Date
1. Keith Haynes
DWQ/ARO 828-251-6208
o®00/O('
C/
ignaturo of eviewer
Agency/Office
Data
DWQ/ARO 828-251-6208
G aD
Regulatory Office Use Only
,ction Taken
Date
Compliance Status
bao- Noncompliance
Compliance

NORTH�AROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
June 9,2000-
Mr. R. L. Ackerman, Environmental Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Subject: Compliance Biomonitoring Inspection
BASF - Enka Plant WWTP
NPDES Permit Number NC0000299
Buncombe County
Dear Mr. Mr. Ackerman
Please find enclosed a copy of the Compliance
Inspection Report for the Biomonitoring Inspection which I
conducted at the subject facility on May 16, and 19, 2000.
The test result and measured water quality parameters
for these samples indicate that the effluent would not be
predicted to have water quality impacts on the receiving
stream. As noted in the attached Report, the test result
was recorded as a "Pass".
If you have any questions concerning the Report, or if
you require any assistance, please do not hesitate to
contact me at 251-6208.
Sincerely,
.r
D. Keith Hayn rr"
Environmental Specialist
Attachment
xc: Jimmie Overtodi
Max Harter7
INTKRmnNGF BUILGING, 58 WCOCFIN PLNCE, AGNIIVILLE, NC 28801-2414
NER28-261-6208 FAX B2B-251-6952
AN EQUAL OPPORTUNITY / AFPIRMATIVE ACTION EMPLGVEN - 50% RECYCLED/10% P02T CUN.O.I N 1P—

United States EnvirL..eental Protection Agency
Washington, D.C. 20460
2040-0003
EPA
FmAppovie"
xpires 7-31-85
NPDES Compliance Inspection Report
Section A: National Data System Coding
Transaction Code NPDES, ybom/day, - Inspection Type Inspector F. Type
I IN 1- _ 215 1 3 1 NC0000299 11- 12 00/05/16 17 18 19 u �$ u
� 2012
u
Remarks
I.I I I I I I I I I I II I I I
Reserved Facility Evaluation Rating BI QA Reserved
67 I I I I69 70 a u I 71 113 onI 72 I N I 73 � 74 75 � 80
I I
Section B: Facility Deal
lame and location of Facility Inspected
Entry Time
Permit Effective Date
IASF CORPORATION
9:50 am
95/12/01
JS HWY 19/23 & NC HWY 112 (SAND HILL RD)
Exit Time/Date
Permit Expiration Date
'.NKA, NC (BUNCOMBE COUNTY)
11:00 am
00/09/30
lamels) of On -Site Represenvolveh)/ride(s)
Phone Nuts)
.AY C. ACKERMAN, ORC & MGR OF ENVIRONMENTAL SAFETY & QUALITY
[phone]
:AY CROWDER/DON CANIPE
Jame, Address of Responsible Official
Title
)R. JACK A DELLINGER
GENERAL MANAGER
IASF CORPORATION
Phone No. Contacted
NKA, N.C. 28728
(828) 667 - 7110 No
action C: Areas Evaluated During Inspection CODES- S- Satisfactory M -Marginal U - Unsatisfactory N - Not evaluataNNol applicable
N
Permit
Records/Reports
Facility Site Review
N
Flow Measurement
Laboramry
Effluent/Receiving Waters
N
Pretreatment
Compliance Schedules
Self Monitoring Program
N
Operations & Maintenance
Sludge Disposal
Other: AQUATIC TOX
N
N
N
N
N
N
N
S
Section D: Summary of Findings/Comments (peach additional sheets if necessary)
)n May 17, 2000, Division Aquatic Toxicology personnel initiated a 3-Brood Cerhodaphnie bodice passttail.toxicity lest on the effluent from the subject W WTP.
he samples were collected on May 16 and 1&19, 2000 by Asheville Regional Office staff.
he result of the test indicated that the subject discharge met criteria set forth in established standards. At the instream waste concentration of (IWC=8.0%),
redicted by the low stream Bow 7010 of 23.0 cis and the permitted discharge volume of 1.25 mgd, 91.7%survival occurred in the test population with an
verage of 22.6 neonates per test organism. The control population exhibited 100%.survival with anaverage. of 24.0.neonates per control organism.. Thus, the
:st was recorded i s a °Pass". Other measured water quality parameter results were: first sample, pH=8.08 $U, conductivity-I130 micromhosturn, TRC=<0.1
ig/I; second sample pH=8.00 SU, conductivity=1060 micromhos/cm, TRC=<0.1 mg/l.
lamels) and Signamrels) spectods)
Agency/OPoce?elephone
Date
I. Keith Haynes
DWQ/ARO 828-251-6208
00001019
ignature of eviewer
Agency/Office
Data
DWQ/ARO 828-251-6208
�D
Regulatory Office Use Only
,coon Taken
Date
Compliance Status
tLNoncompliance
e Compliance

,l Corporation
O May12, 2000
c F BASF
(a-/ F- L
DVVQ
Mr. James W. Meyer LABORATORY SECTION
Laboratory Section n
Division of Water Quality�3
NC DENR
1623 Mail Service Center
Raleigh, INC 27699-1623
Re: Laboratory Certification Maintenance Inspection
Dear Mr. Meyer:
This is in response to your letter of April 12, requesting a written response to
specific violations, recommendations, and comments in regards to our annual
Laboratory Certification Inspection.
Let me begin by saying that I too am concerned over the cited previously
violations found by Mr. Francies. While I am not making excuses for these
deficiencies, I would like to explain that these items were corrected last year by
Mr. Ross Peebles as I indicated to you in my response to you. However, on
March 1, 2000 we discontinued the staffing of our Laboratory and contracted with
Pace Analytical, Inc. to provide a technician to run the analyses required by our
plant and our NPDES Permit. Mr. Glenn Howell, one of our former QC
Laboratory Technicians, was hired by Pace and has been working in our
Laboratory since then. I was mistaken in my assumption that since Mr. Howell
had relieved Mr. Peebles during vacations that he was fully informed of all the
procedures in the Lab, including the QC requirements. Obviously he was not, as
all of our deficiencies are related to quality control items.
We will make every effort to run our Laboratory in a manner that meets all the
requirements for the properenalysis,of samples, good quality control practices,
and proper documentation of res,Vts and other required data. Itemized corrective
actions are attached. ("�� R . r6 2 r 7
Sincerely, tW'(
MAY 18 OOnZ ; 2—
ASNEVI" AREGIONE""NICE
fa7Ackerman
Laboratory Supervisor
Sand Hill Road. P.O. Sox 669, Enka, North Carolina 28728-0669 f828) 667-7110

Correction actions taken are as follows
III. A. - Since our inspection, only ink has been used in the lab to record results
and other documentation. Errors are crossed out and initialed.
III. B. —A reagent preparation log is being maintained to record the preparation of
all reagents, standards, and media. Each entry will be under a heading which will
identify the manufacturer, lot number and expiration date. Any certificates of
analysis received will be retained by the Lab for three years.
Residual Chlorine and Ammonia Nitrogen
C. Every six months a 5-point regression curve will be prepared for the tests and
a mid -range standard will be prepared from a second source to run along with
the samples for control purposes.
D. 1. The use of the control sample as described in c. above should improve
significantly the accuracy of our data. When a greater than 10 % variance occurs,
corrective action will be taken.
D, 2. The value of the control standard will be calculated and recorded in all
future analyses.
TSS
3. An annual determination of the time required to dry samples to a constant
weight will be performed and documented. The time in and time out of the oven
will be recorded for all analyses in the future.
Fecal Coliform
4. — Samples containing chlorine are being dechlorinated when taken and tested
for chlorine upon reaching the Lab. If samples are detected out of limits the state
will be notified.
5. — The maximum holding temperature thermometer will be used exclusively and
its readings documented.
BOD
F. — The BOD bottles are being randomly chosen for use and cleaned weekly.
6. In the future, if the BOD of the glucose-glutamic acid standard is outside of
the accepted control limit range of 198 ± 30.5, the data will be qualified and the
problem corrected.

7. Unfrozen Polyseed will be used with buffered dilution water to seed material
for BOD analyses. Sufficient material will be used to give a seed correction in the
range from 0.6 to 1.0 mg/I.
8. In the future if quality control requirements are not met, the data will be
qualified on the DMR. The DO readings that we do on the permitted outfall are
now being recorded on the DMR.
RLA
5-12-00

r)
Division of Water Quality
May 24, 2000
To: Forrest Westall
Water Quality Supervisor, ARO
Through: Matt Matthews (^r�
Supervisor, Aquatic Toxicology Unit
From: Sandy Mort 4K
Quality Assurance Officer, Aquatic Toxicology Unit
Subject: Whole effluent toxicity test results
BASF
NPDFS Permit # NC0000299/001
Buncombe County
The aquatic toxicity test using grab and 24-hour composite samples of effluent discharged from
BASF has been completed. BASF has an effluent discharge permitted at 4.0 million gallons per
day (MOD) entering Hominy Creek (7Q10 of 23.0 CPS). Whole effluent samples were collected
on May 16 (grab) and 19 (24-hour composite) by Keith Haynes for use in a chronic
Ceriodaphnia dubia pass/fail toxicity test. The test using these samples resulted in a pass.
Toxicity test information follows.
Test Type
Test Concentrations
Test Result
Control Survival
Control Mean Reproduction
Test Treatment Survival
Treatment Mean Reproduction
First Sample pH
First Sample Conductivity
First Sample Total Residual Chlorine
Second Sample pH
Second Sample Conductivity
Second Sample Total Residual Chlorine
3-Brood Ceriodaphnia dubia pass/fail
8% sample
Pass
100%
24.0 neonates
91.7.%a
22.6 neonates
8.06 SU
1130 micromhos/cm
<0.1 mg/l
8.00 SU
1060 micromhos/cm
<0.1 mg/1
Test results for these samples indicate that the effluent would not be predicted to have water
quality impacts on receiving water. Please contact us if further effluent toxicity monitoring is
desired. We may be reached at [phone].
Basin: FRB02
cc: Central Files
Environmental Sciences Branch Water Qmlity Section

. urporation (�
D pQ
May 18, 2000
Mr. James W. Meyer
Laboratory Section
Division of Water Quality NC DENR
1623 Mail Service Center
Raleigh, NC 27699-1623
Re: DMR-QA Study 19 Chronic Toxicity "Not Acceptable
Permit No. NC 0000299
Dear Mr. Meyer:
BASF
filli;CEO I1IE
i)�
nn
UVQ
LAt? mTORl Qicum
Enclosed please find a copy of a letter from Ms Jennifer Jones, Aquatic
Toxicology Laboratory Supervisor at Pace Analytical in Asheville, containing their
explanation for the "Not Acceptable" results received on the referenced DMR-QA
Study 19 for Ceriodaphnia Dubia Chronic Toxicity Test.
We have used Pace Analytical exclusively for this test for at least the past ten
years and have had mostly successful results with their analyses. Given the
stated corrective action, we see no reason to change laboratories at this time.
We trust that this is a satisfactory conclusion to this matter. If not, I can be
reached at [phone] or by e-mail at [e-mail].
Sincerely,
/4 1�
Ray Ackerman
Laboratory Supervisor
Sand HIII Road, P.O. Box 669, Enka, North Carolina 28728-0669 [phone]

_. .Analytical-r-)
May 11, 2000
Pace Analytical Services, Inc.
54 Ravenscroft Drive
Asheville, NC 28801
Phone: [phone]
Fax: [phone]
Re: DMR-QA Study 19-Ceriodaphnia dubia Chronic Test "Not Acceptable"
Results. Data review, summary & corrective actions.
Dear Valued Client,
We have completed a thorough review of all testing procedures and benchsheetsused
during the testing of the DMR-QA 19 sample for which we received a "Not Accept" for
the reproduction of the Ceriodaphnia dubia chronic test. We reported a NOEC at 6.25%
which was outside the acceptable range of 12.5% to 50%. After reviewing the bench
sheets from the initial DMR-QA Study 19 we determined that not all of the batches of
moderately hard synthetic water were allowed to age for a full 48 hours, as specified in
the instructions, before being used in the test.
in order to confirm that this was a factor, we reanalyzed the remaining toxicant sample
with water which was allowed to mix for a full 48 hours and obtained "acceptable
results." No other factors could be found which would have caused an incorrect NOEC
to be reported. Reference toxicant tests were run within one week of both DMR-QA tests
and fell within acceptable ranges.
The data from the DMR-QA Study rerun is available upon request. If you have any
questions please feel free to contact me at [phone].
'Sincerely,
`Jennifer Jones
Aquatic Toxicology Laboratory Supervisor
Note: A copy of our findings should be forwarded to the DMR coordinator by June 6, 2000.

corporation - cn
F
BASF
tr/4F- L
- D pal i
May 12, 2000 MY 15 2000 Pkq N G 3
G
Mr. James W. Meyer LABORATORY SECTION
Laboratory Section n
Division of Water Quality ,4- q 3 1
119011 M
1623 Mail Service Center
Raleigh, NC 27699-1623
Re: Laboratory Certification Maintenance Inspection
Dear Mr. Meyer:
This is in response to your letter of April 12, requesting a written response to
specific violations, recommendations, and comments in regards to our annual
Laboratory Certification Inspection.
Let me begin by saying that I too am concerned over the cited previously
violations found by Mr. Francies. While I am not making excuses for these
deficiencies, I would like to explain that these items were corrected last year by
Mr. Ross Peebles as I indicated to you in my response to you. However, on
March 1, 2000 we discontinued the staffing of our Laboratory and contracted with
Pace Analytical, Inc. to provide a technician to run the analyses required by our
plant and our NPDES Permit. Mr. Glenn Howell, one of our former QC
Laboratory Technicians, was hired by Pace and has been working in our
Laboratory since then. I was mistaken in my assumption that since Mr. Howell
had relieved Mr. Peebles during vacations that he was fully informed of all the
procedures in the Lab, including the QC requirements. Obviously he was not, as
all of our deficiencies are related to quality control items.
We will make every effort to run our Laboratory in a manner that meets all the
requirements for the proper analysis of samples, good quality control practices,
and proper documentation of res irs- �and other required data. Itemized corrective
actions are attached. I I I n�
Sincerely, ' nl
I� �Ju �tav a coot
UIBORATORY SECTI01
IISHEYILIE flEGIONAI OF
Ra Ackerman
Laboratory Supervisor
Sand Hill Road, P.O. Box 669, Enka, North Carolina 28728-0869 [phone]

1
Correction actions taken are as follows
Ill. A. - Since our inspection, only ink has been used in the lab to record results
and other documentation. Errors are crossed out and initialed.
III. B. — A reagent preparation log is being maintained to record the preparation of
all reagents, standards, and media. Each entry will be under a heading which will
identify the manufacturer, lot number and expiration date. Any certificates of
analysis received will be retained by the Lab for three years.
Residual Chlorine and Ammonia Nitrogen
C. Every six months a 5-paint regression curve will be prepared for the tests and
a mid -range standard will be prepared from a second source to run along with
the samples for control purposes.
D. 1. The use of the control sample as described in c. above should improve
significantly the accuracy of our data. When a greater than 10 % variance occurs,
corrective action will be taken.
D. 2. The value of the control standard will be calculated and recorded in all
future analyses.
TSS
3. An annual determination of the time required to dry samples to a constant
weight will be performed and documented. The time in and time out of the oven
will be recorded for all analyses in the future.
Fecal Coliform
4. — Samples containing chlorine are being dechlorinated when taken and tested
for chlorine upon reaching the Lab. If samples are detected out of limits the state
will be notified.
5. — The maximum holding temperature thermometer will be used exclusively and
its readings documented.
BOD
F. — The BOD bottles are being randomly chosen for use and cleaned weekly.
6. In the future, if the BOD of the glucose-glutamic acid standard is outside of
the accepted control limit range of 198 t 30.5, the data will be qualified and the
problem corrected.

7. Unfrozen Polyseed will be used with buffered dilution water to seed material
for BOD analyses. Sufficient material will be used to give a seed correction in the
range from 0.6 to 1.0 mg/I.
8. In the future if quality control requirements are not met, the data will be
qualified on the DMR. The DO readings that we do on the permitted ouffall are
now being recorded on the DMR.
RLA
5-12-00

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
May 19, 2000
239
MR. RAY ACKERMAN
BASF CORP - FIBERS DIV
SAND HILL ROAD
ENKA, NC 28728
Dear Mr. Ackerman:
Your letter received May 15, 2000 that describes
corrective actions for your analytical procedures has
been reviewed. The actions taken are acceptable for
your North Carolina Wastewater/Groundwater laboratory
certification. If a future inspection should reveal
that the violations cited in the inspection report were
not corrected, enforcement actions will be recommended.
Thank you again for your cooperation. Contact us
at (828)-251-6208 extension 285 if you have questions.
Sincerely,
G 0�' %-t C ;
Gary Francies
Laboratory Section
cc: James W. Meyer
Marilyn Deaver
I. 6®
rrRsr
INTE RCMANOH a." ..... 8B WOOO FIN PLACB. AEXEVILLB, NORTH 0... LINP 39801-Y419
P XONE"a".1-BEOB FAY81E$81-84Mi
AN EQUAL OPPORTUNITY / APFIRMATIVE ACTION EMPLOYER - .0% RECYCLED/10% Po9T <ONeYMER PwPex

n
r�
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
MR. JACK A. DELLINGER, PHD
SAND HILL ROAD
ENKA, NC 28728
Dear Mr. Jack A. Dellinger:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
May 5, 2000
g
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
BASF CORPORATION ENKA PLANT
BUNCOMBE COUNTY
PERMITNO: N00000299
LV 00-086
This letter is to acknowledge receipt of check No. 4250989 in the amount of $323.11 received from
you dated May 05, 2000. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations or Permits.
If you have any questions, please call Rob Lang at [phone].
Sincerely,
l9
�y
J' E. Shannon Langley, Supervisor
Point Source Compliance/Enforcement Unit
Cc: Enforcement File #: LV 00 -086
ARO Regional Office Supervisor
Central Files
1617 Mail Servim Center,
3 Fax
An Equal iTelephone
l Opportunity Aairmative Action Employer 50%recycled/10% pos12
Fwnsumer Paper

`GRa
!
QBeg
;
gow
,,.1....,
I
TINT
:caaece\Sc
-
S!
!\
�\)..
;
:
)
n3o
{
_
!§;
ng
{�
�}
)
}-
!
|
ocoM
\
{;]
/
\
`{
�(!
;
«
J\
!}I§
y

p
Q
g
x
o
_
°
N
y+
N
gS
a
e
^
s
as
F
2
aw
�
R
i
3
3
a
pg!
°
#
N
e
q�
a
F
�g
4
II
ol, �j 1 B 1 1 4 M DIJ �Io SI O wI I
N
lel11ti11mlpi%l=lel%°II'll 1l3lSill xl=I�
a
x
91 ses Milt
9
C
0
0
0
x
x

\\77
pi;
!
|Raa!/
�\
;
!i
......
f
.
;l,:
�RGeE!
b\
WO
-
\
}
;
gE0
!:>
OO{
(`}
)
{{
\\
{}}\

'
!
!
:
\
!
!
§
||
{
|
i
!|
r-
t
!
�.
I
.
.
�.
�
!
.
,
4IlIlIllllllll!
•.
!!..
,!!!
§2
|
|
§
!!!!
»
of
Mm

{;a
JAME9 B. HUNT JR} 5�
�I GOVERNOR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
April 12, 2000 DIVISION OF WATER QUALITY
239
Mr. Ray Ackerman
BASF Corporation - Enka Plant
Sand Hill Road
Enka, NC 28728
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr. Ackerman:
Enclosed is a report for the inspection performed on March 29, 2000
by Mr. Gary W. Francies. Within thirty days, please supply this office with a
written item for item description of how these violations were corrected. A
response is not required for comments or recommendations unless
specifically requested. We are seriously concerned about the CITED
PREVIOUSLY violation(s) found during the inspection. Another inspection
will be scheduled within 3 to 6 months. If the violations cited in the enclosed
report are not corrected, enforcement actions will be recommended. For
certification maintenance, your laboratory must continue to carry out the
requirements set forth in 15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be
requested from this office. Thank you for your cooperation during the
inspection. Please contact us at 919-733-3908 if you have questions or
need additional information.
Sincerely,
James W. Meyer
Laboratory Section
Enclosure
cc: Marilyn O. Deaver
Gary W. Francies
�Asheville,l�ea isl�l_
LABORATORY SECTION
9_.623
1629 MAIL SERVICE NIIIR, RALEIGH, NORTH CAROL INA 27688-1E23
LocgTlaryl 4406 REEDY CREEK ROAD, RAL¢IGH, NORTH CAx OLINA 27607-6446
P% RE YCLED/J02906 FAX 9L.K PAPER
AN EQUAL OPPORTUNITY / AnIIpMRIVE ACTION EMPLOYER - 60% RECYCLED/IO% P08T <ONeUM¢P PAPER
cv..e%.V.S Waf

LABORATORY NAME:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
EVALUATOR(S):
ON -SITE INSPECTION REPORT
BASF Enka Plant
Sand Hill Road
Enka, NC 28728
239
3/23/00
Maintenance
Gary Francies
LOCAL PERSON(S) CONTACTED: Ray Ackerman, Butch Howell
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A
NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory is spacious and adequately equipped. All equipment is well
maintained. Since zinc samples are no longer analyzed in the laboratory, it is
recommended that the lab drop certification for zinc. Several violations noted in
the last inspection have not been corrected. It appears this happened because of
personnel changes made in March 1999, shortly after the inspection. It appears that
the new analyst was not properly trained and since then, there has been a lack of
supervision of the laboratory. Some further quality control procedures need to be
implemented.
Samples were split with the following results:
Fecal Coliform performance sample:
Enka Laboratory State Laboratory
284/100 ml 215/100 ml
Composite Effluent samples:
HOD, mg/l 11.4 13.5
TSS, mg/1 19 18
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
Bench Sheets
A. COMMENT: Most documentation is performed with pencil. Good laboratory
practices dictate that all data be recorded on the worksheets, logbooks, and DMRS in
black (preferred) or blue ink. No white out or write overs of errors are allowed.
Any error must be crossed out with one ink line and the correction and analyst
initials placed near the error. A written responae is required.
General
B. RECOMMENDATION: It is recommended the laboratory increase the documentation of
reagent and standard preparation. The preparation of all reagents, standards and
media should be documented in a preparation log or logs. Traceable identifiers
should link solution preparation information to analytical batches in which the
solutions are used. Documentation of solution preparation should include the
analyst's initials, date of preparation, the volume or weight of standard used, the
solvent, and final volume of the solution. This information as well as the vendor,

age 2
manufacturer, lot number, certificate of analysis, and expiration date should be
retained for primary standards or chemicals used. A written response is required.
COMMENT: The lab has a reagent preparation log, but it is only sporadically used and
many items are not documented.
Residual Chlorine and Ammonia Nitrogen
C. COMMENT: The laboratory control standard is not from a second source. A
written response is required.
REQUIREMENT: Analyze one known standard in addition to calibration standards each
day samples are analyzed to document accuracy. This laboratory control standard must
be from a second source. For held curves for calorimetric methods, it must be
analyzed after the calibration verification standard is analyzed. It is recommended
that this laboratory control standard, like the calibration verification standard,
have a mid -range concentration and not vary by more than ± 10%. If it does, the
analysis is out of control. The analysis must be terminated and the problem
corrected. Ref: 15A NCAC 2H .0805 (a) (7) (B), (F), and Standard Methods, 18th
Edition - Method 1020 B.S.
Ammonia Nitrogen
D. COMMENTS: The linearity of the curve is not easily determined.
Recommendation: It is strongly recommended that a linear regression be calculated to
document accuracy of the method and reliability of the curve. Document the linearity
of the curve (correlation coefficient) on the hench sheets with proper initials and
dates. Good laboratory procedures require a correlation coefficient greater than
0.995. Reference: 15A NCAC 2H .0805 (a) (7) (H). Determine the absorbance
against the concentrations of standards to establish a working curve and the
agreement with Beer's law. Ref: Standard Methods, 18 Edition - Method 1070D pg. 1-
28. To establish agreement with Beer's law, a correlation coefficient must be
calculated to document linearity. For selective ion electrodeanalysis, a slope may
be documented each time samples are analyzed.
1. VIOLATION: The values obtained on the laboratory control standards indicate a
possible problem. The following values were obtained on 0.5 mg/1 laboratory control
standards (all values are mg/1): 3/10/99=0.92, 3/17/99=0.93, 9/19/99=0.93,
6/30/99=0.99, 8/18/99-0.59. Five of the last sixty-two sample sets had questionable
results.
REQUIREMENT: See requirement for comment letter C above. And: Any time quality
control results indicate an analytical problem, the problem must be resolved and any
samples involved must be reanalyzed if the holding time has not expired. Reference:
15A NCAC 2H .0805 (a) (7) (F).
2. VIOLATION: The value obtained for the laboratory control standard is not
always calculated and documented.
REQUIREMENT: Supporting records shall be maintained as evidence that these practices
are being effectively carried out. All analytical records must be available for a
period of three years. Ref: 15A NCAC 2H .0805 (a) (7) and (a) (7) (G).
COMMENT: In order to document accuracy, the value of the laboratory control standard
must be calculated and documented. In eight of sixty-two sample sets the value was
not calculated.
TSS
3. VIOLATION: The adequacy of the drying time has not been verified. The time
samples are placed in the oven and the time samples are removed is not documented.
Cited in previous inspection.

Page 3
REQUIREMENT: If each sample is not redried"and reweighed, the laboratory may verify
that a specific drying time is adequateto dry samples to constant weight. This
verification may be performed 'annually.. by drying representative samples for a
determined time period and verifying that this time period is adequate with
additional drying and weighing cycles. This annual check must be documented.
-
Additionally, the time samples are placed, in the oven and the time samples are
removed from the oven must be recorded for each analysis thereafter. Ref: Standard
Methods 18th Edition; Method 2540 D. 36. 'and 15A NCAC 2H .0805 (a) (7)and (a) (7)
(D),
Fecal Coliform --
4. VIOLATION: Sample preservation is not properly performed and documented. Cited
in previous inspection
REQUIREMENT: Samples received for analysis"must be verified and documented to have
been properly preserved. Samples containing chlorine must be dechlorinated at the
time of sample collection and treated according to the requirements of the analysis.,
to be performed. Upon receipt_ in the laboratory, samples must be checked and..
documented to be free of chlorine. A variety of testing kits are considered to be
adequate for most chlorine interference 'checks and a maximum detection limit of 0.2
mg/L is allowed. When samples are received out of compliance, the lab must inform
the client and the State of NC in writing. Ref: 15A NCAC 2H .0805 (a) (1) and (7)
(M) and (N) .
5. VIOLATION: It is not possible to distinguish from the autoclave log which days
the temperature gage is used and which days the maximum holding thermometer is used.
REQUIREMENT: Supporting records shall be maintained asevidence that these practices
are being effectively carried out. All analytical records must be available for a
period of three years. Ref: 15A NCAC 2H .0805 (a) (7) and (a) (7) (0).
REQUIREMENT: It is required that the operating temperature of the autoclave be
checked with a maximum holding thermometer at least once per week. Ref: Standard
Methods, 18th Edition - Method 9020 B.2i.
E. RECOMMENDATION: It is recommended that each lot of media be checked to confirm
the required pH.
REQUIREMENT: The pH of the media must be 74 t 0.2 after sterilization and cooling.
Incorrect pH values may indicate 'a problem with reagent water quality, medium
deterioration, or improper preparation. Ref': Standard Methods, 18th Edition - Method
9020 B. 3h 1.
BCD .
F. COMMENT; The bottles used for the dilution water blank, seed blank, seed
controls, glucose-glutamic acid standard,.: and samples are dedicated, i.e. the same..
bottle is used each time for that particular item. A written response is required.
REQUIREMENT: The bottles be randomly selected and rotated. This is the only way to
assess whether bottles are being adequately cleaned.
G. COMMENTS: The BOD bottles appeared„to be dirty. When the bottle dedicated to
the dilution water blank was compared tq,.the rest of the bottles,. it was apparent
the bottles needed cleaning. The bottle�,tq'be used the day of the inspection were
then cleaned before they were used that day.
RECOMMENDATION: It is strongly recommend 'that the bottles be cleaned thoroughly
after each use. Besides detergent and water, an occasional cleaning with chromerge
or acid may be needed.
6. VIOLATION: The value obtained for ,the glucose-glutamic acid standard is often
unacceptable. No evidence of corrective action is apparent.

Page 4
REQUIREMENT: It is required that whenever the SOD of the glucose-glutamic acid
standard is outside the accepted control limit range (198 ± 30.5) the data from that
set must be qualified. Ref: Standard Methods, 18th Edition - Method 5210 B.6a, And
REQUIREMENT: Any time quality control results indicate an analytical problem, the
problem must be resolved and any samples involved must be reanalyzed if the holding
time has not expired. Reference: 15A NCAC 2H .0805 (a) (7) (F).
COMMENTS: Twenty-three of the last thirty-eight sets had unacceptable standards
outside the acceptable limits.
7. VIOLATION: The seed correction factor is erratic and often unacceptable. No
evidence of corrective action is apparent. Cited in previous inspection
REQUIREMENT: Sufficient seed material must be used to yield a seed correction of 0.6
to 1.0 mg/l. Ref: Standard Methods, 18th Edition - Method 5210 B. 4d 2.
REQUIREMENT: Any time quality control results indicate an analytical problem, the
problem must be resolved and any samples involved must be reanalyzed if the holding
time has not expired. Reference: 15A NCAC 2H .0805 (a) (7) (F).
COMMENTS: Thirteen of the last thirty-eight sample sets were unacceptable. Frozen
Polyseed is used, made with distilled water. Polyseed must be made with buffered
dilution water and it is strongly recommended that it not be frozen.
8. VIOLATIONS: When all method quality control requirements are not met, the
reported data are not qualified. Cited in previous inspection
Requirement: It is the desire of the State of North Carolina that all data generated
for any permitted location under NPDES requirements is to be reported. "Every person
subject to [15A NCAC 2B .05061 shall file certified monitoring reports setting forth
the results of tests and measurements conducted pursuant to NPDES permit monitoring
requirements." Ref: 15A NCAC 2B .0506 (a) (1). Additionally, "the results of all
tests of the characteristics of the effluent, including but not limited to NPDES
Permit Monitoring Requirements, shall be reported on monthly report forms." Ref: 15A
NCAC 2B .0506 (b) (3) (J).
The NPDES Permit itself states in Part II, Section D, Monitoring and Records, Number
7 - Recording Results, "for each measurement or sample taken pursuant to the
requirements of this permit, the permittee shall record the following
information... the results of such analyses."
This means all data are reported and none are rejected. If all quality control
requirements are not met, it is required that the data is qualified and the
qualification appears on the back of the Discharge Monitoring Report (DMR).
Any rejection of .data from the storets will be issued by the agency, which receives
the data.
The Quality Control requirements of the method are outlined below:
1. The DO depletion of the dilution water blank must not be more than 0.2 mg/l.
2. The seed controls must deplete at least 2.0 mg/1 DO and have at least 1.0 mg/l
DO remaining.
3. The samples must also deplete at least 2.0 mg/l DO and have at least 1.0 mg/l
DO remaining.
9. No evidence of toxicity should be present. This can only be evident when at
least three dilutions are analyzed. This is characterized by an increasing BOD
value as the sample concentration decreases.
5. The glucose glutamic acid standard must be in the acceptable range of 198,mg/l
+ 30.5 mg/l.
6. The seed correction, calculated from the seed controls, must be between 0.6
and 1.0 mg/l.
Anytime any of the above quality control requirements are not met, the data must be
qualified. The qualifying statement should indicate how QC requirements were not met
and indicate whether the data is valid. But the data must always be reported.

Page 5
IV. PAPER TRAIL: -
A review of data was conducted. This consisted of comparing laboratory bench sheets
and contract lab reports to DMRs submitted tp this Division. Data were reviewed for
these months: September, November 1999, and January 2000. No errors were noted. It
appears the facility is doing a good job of accurately transcribing data.
V. CONCLUSION:
We are concerned with the violation(s) that were cited previously and not corrected.
Failure to correct the violation(s) cited in this report will lead to enforcement
action.
Ref: 15A NCAC 2H .0607 (a) (1) and (14) -
Laboratory Decertification:
A laboratory may be decertified for any or all parameters for up to one year for any
or all of the following infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or
quality control program as set forth in the application, and these Rules; or
(14) Failing to comply with any other terms, conditions, or requirements of this
Section or of a laboratory certification.
Correcting the above violations should help to produce quality data and meet'
certification requirements. Implementing the recommendations will further improve
the quality of the data. Another inspection will be conducted in three to six
months.
Report prepared by: Gary Francies Date: 3/29/00
a

State of North Carolina
Department of Environment and Natural Resources
Division of Water Quality
59 Woodfin Place Asheville, North Carolina 28801
April 19, 2000
CERTIFIED MAIL
Mr. Ray Ackerman
BASF Corporation - Enka '
Sand Hill Road
Enka, North Carolina 28728
SUBJECT: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0000299
BASF Corporation W WTP
Buncombe County
Dear Mr. Ackerman:
This is to inform you that a review of your toxicity self -monitoring report form for the month of
February 2000 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent
toxicity violation(s). Yom efforts may include conducting a Toxicity Reduction Evaluation (TRE) which is a
site -specific study designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity,
evaluate the effectiveness of toxicity control options, and then confirm reductions in effluent toxicity. Please be
aware that North Carolina General Statutesprovidefor assessment of civil penalties for violations of NPDES
permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note updated mailing addresses for submitting your Discharge
Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review this
information and if it would be helpful to discuss this situation or possible solutions to resolve effluent toxicity
noncompliance, please contact Mr. Keith Haynes with this office at [phone].
Sincerely,
;;Ftiww �
Regional Water Quality Supervisor
cc: Keith Haynes -Asheville Regional Office
Aquatic Toxicology Unit
Central Files

ON -SITE INSPECTION REPORT
LABORATORY NAME: BASF Enka Plant
ADDRESS: Sand Hill Road
Enka, NC 28728
CERTIFICATE $: 239 / / /
DATE OF INSPECTION: 3/23/00
TYPE OF INSPECTION: Maintenance
EVALUATOR(S): Gary Francies
LOCAL PERSON(S) CONTACTED: Ray Ackerman, Butch Howell
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A
NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL C0MMENTS:
The laboratory is spacious and adequately equipped. All equipment is well
maintained. Since zinc samples are no longer analyzed in the laboratory, it is
recommended that the lab drop certification for zinc. Several violations noted in
the last inspection have not been corrected. It appears this happened because of
personnel changes made in March 1999, shortly after the inspection. It appears that
the new analyst was not properly trained and since then there has been a lack of
supervision of the laboratory. Some further quality control procedures need to be
implemented.
Samples were split with the following results:
Fecal Coliform performance sample:
Enka Laboratory State Laboratory
284/100 ml 215/100 ml
Composite Effluent samples:
BOD, mg/l 11.4 13.5
TSS, mg/1 19 18
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
Bench Sheets
A. COMMENTS: Most documentation is done with pencil. Good laboratory practices
dictate that all data be recorded on the worksheets, log books, and DMRs in ink. No
white out or write overs of errors is allowed. Any error must be crossed out with
one ink line and the correction and analyst initials placed near the error.

age 2
General
B. Recommendation:_ It is recommended the laboratory increase the'jl.documentation of
Vreagent and... standard preparation.,' The preparation of all reagents, standards and
media should be documented in a preparation log or logs. Traceable identifiers
should link solution preparation information to analytical batches in which the
solutions are used. Documentation of solution preparation should include the
analyst's initials, date of preparation, the volume or weight of standard used, the
solvent and final volume of the solution. This information as well as the vendor,
manufacturer, lot number, certificate of analysis and expiration date should be
retained for primary standards or chemicals used..
COMMENTS: The lab has a reagent preparation log but it is only sporadically used and
many items are not documented.
Residual Chlorine-andAmmonia-:Nitrogen
C. COMMENTS: The laboratory control standard is not from a second source.
REQUIREMENT: Analyze one known standard in addition to calibrationstandards each
-day .samples. are analyzed to document accuracy. This laboratory control standard must'
be from a second source. For held curves for colorimetric methods, it must be
analyzed after the calibration verification standard is analyzed. It is recommended
that this laboratory control standard, like the calibration verification standard,
have a mid -range concentration and not vary by more than 1 10%. If it does the
analysis is out of control. The analysis must be terminated and the problem
corrected. Ref: 15A NCAC 2H .0805 (a) (7) (B), (F), and Standard Methods, 18th
Edition - Method 1020 B.3. A written response is required.
kAmmonia-NitrogeM--'
D. COMMENTS: The linearity of the curve is not easily determined.
Recommendation: �It is strongly recommended that a linear regression tie calculated)to
document accuracy of the method and reliability of the curve. Document the linearity
of the curve (correlation coefficient) on the bench sheets with proper initials and
dates. Good laboratory procedures require a correlation coefficient greater than
.995:"Re nce: 15A NCAC 2H .0805 (a) (7) (H).
L/p1/ VIOLAT IO The values obtained on the laboratory control standards indicate a
posse em. The following values were obtained on 0.5 mg/1 laboratory control
stanear (all values are mg/1): 3/10/99=0.42, 3/17/99-0.43, 4/14/99=0.43,
6/30/99-0.44, 8/18/99=0.59. Five of the last sixty-two sample sets had questionable
results.
REQUIREMENT: See requirement for comment letter C above. And: Any time quality
control results indicate an analytical problem, the problem must be resolved and any
s
aOes involved must be reanalyzed if the holding time has not expired. Reference:
15 H .0805 (a) (7) (F).
VIOLATIO The value obtained for the laboratory control standard is not
alwa ca ten and documented.
REQUIREMENT: Supporting records shall be maintained as evidence that these practices
are being effectively carried out. All analytical records must be available for a
period of three years. Ref: 15A NCAC 211 .0805 (a) (7) and (a) (7) (G).

.,age 3
COMMENTS: In order to document accuracy, the value of the laboratory control
standard must be calculated and documented. In eight of sixty-two sample sets the
value was not calculated.
TSS
3. VIOLATION: The adequacy of the drying time has not been verified. The time
samples are placed in the oven and the time samples are removed is not documented.
Cited in previous inspection.
REQUIREMENT: If each sample is not redried and reweighed, the laboratory may verify
/that a specific drying time is adequate to dry samples to constant weight. This
1/ that
may be performed annually by drying representative samples for a
determined time period and verifying that this time period is adequate with
additional drying and weighing cycles. This annual check must be documented.
Additionally, the time samples are placed in the oven and the time samples are
removed from the oven must be recorded for each analysis thereafter. Ref: Standard
Methods 18th Edition; Method 2540 D. 3c. and 15A NCAC 2H .0805 (a) (7)and (a) (7)
(D)•
4ecal Coliform
9. VIOLATION: Sample preservation is not properly performed and documented. Cited
in previous inspection
REQUIREMENT: Samples received for analysis must be verified and documented to have
been properly preserved. Samples containing chlorine must be dechlorinated at the
time of sample collection and treated according to the requirements of the analysis
performed.
Upon receipt in the laboratory, samples must
be
checked and
umented to be
free of chlorine. A variety of testing kits are
considered
to be
44be
quate for most
chlorine interference checks and a maximum detection
limit
of 0.2
L is allowed.
When samples are received out of compliance, the
lab
must
inform
the client and the State of NC in writing. Ref: 15A NCAC 2H .0605 (a) (1) and (7)
(M) and (N).
5. VIOLATION: It is not possible to distinguish from the autoclave log which days
the temperature gage is used and which days the maximum holding thermometer is used.
REQUIREMENT: Supporting records shall be maintained as evidence that these practices
are being effectively carried out. All analytical records must be available for a
Aof three years. Ref: 15A NCAC 2H .0805 (a) (7) and (a) (7) (G). and
✓ REQUIREMENT: It is required that the operating temperature of the autoclave be
checked with a maximum holding thermometer at least once per week. Ref: Standard
Methods, 18th Edition - Method 9020 B.2i.
E. Recommendation: It is recommended that each lot of media be checked to confirm
the required pH.
REQUIREMENT: The pH of the media must be 7.4 i 0.2 after sterilization and cooling.
Incorrect pH values may indicate a problem with reagent water quality, medium
deterioration, or improper preparation. Ref: Standard Methods, 18th Edition - Method
9020 B. 3h 1.
BOD I
E. COMMENT: The bottles used for the dilution water blank, seed blank, seed
controls, glucose-glutamic acid standard, and samples are dedicated, i.e. the same
bottle is used each time for that particular item.

Page 4
RECOMMENDATION: It is strongly recommended that the bottles be randomly selected and
rotated. This is the only way one can assess whether bottles are being adequately
cleaned.
G. COMMENTS: The BCD bottles appeared to be dirty. When the bottle dedicated to
the dilution water blank was compared to the rest of the bottles, it was apparent
the bottles needed cleaning. The bottles to be used the day of the inspection were
then cleaned before they were used that day.
RECOMMENDATION: It is strongly recommended that the bottles be cleaned thoroughly
after each use. Besides detergent and water, an occasional clean with chromerge or
acid may be needed.
6. VIOLATION: The value obtained for the glucose-glutamic acid standard is often
unacceptable. No evidence of corrective action is apparent.
REQUIREMENT: It is required that whenever the BOD of the glucose-glutamic acid standard
is outside the accepted control limit range (198 } 30.5) the data from that set must be
:qualified. Ref: Standard Methods, 18th Edition - Method 5211 B.6a. And REQUIREMENT:
Any time quality control results indicate an analytical problem, the problem must be
resolved and any samples involved must be reanalyzed if the holding time has not
expired. Reference: 15A NCAC 2H .0805 (a) (7) (F).
COMMENTS: Twenty-three of the last thirty-eight sets had unacceptable standards
outside the acceptable limits.
7. VIOLATION: The seed correction factor is erratic and often unacceptable. No
evidence of corrective action is apparent. Cited in previous inspection
/ REQUIREMENT: Sufficient seed material must be used to yield a seed correction of 0.6
to 1.0 mg/l. Ref: Standard Methods, 18th Edition - Method 5210 B. 4d 2. And
REQUIREMENT: An time quality control results indicate an analytical problem, the
problem must resolved and any samples involved must be reanalyzed if the holding
time has not expired. Reference: 15A NCAC 2H .0805 (a) (7) (F).
COMMENTS: Thirteen of the last thirty-eight sample sets were unacceptable. Frozen
Polyseed is used, made with distilled water. Polyseed must be made with buffered
dilution-waUer_and it is strongly recommended that it not be frozen.
8 VIOLATION:6W n all method quality control requirements are not met, the
r[F(,ported. not qualified. Cited in previous inspection
Requ�'�rt2n'�It is the desire of the State of North Carolina that all data generated
for any permitted location under NPDES requirements is to be reported. "Every person
subject to [15A NCAC 2B .0506]shall file certified monitoring reports setting forth
the results of tests and measurements conducted, pursuant to NPDES _permit monitoring)
requirements. Ref:. -15A NCAC 2B .0506-.,(a) (1)._ Additionally, "the results of all r
tests of the characteristics of. the.eff uentp!-includingbut .not limited to NPDES
Permit.. Monitoring Requirements, shall.. be reported on monthly report forms." Ref: 15A?
NCAC 2B .0506 (b) (3) (J).
The NPDES Permit itself states in Part II, Section D, Monitoring and Records, Number
7 - Recording Results, "for each measurement or sample taken pursuant to the
requirements of this permit, the permittee shall record the following
information... the results of such analyses."
This means all data are reported and none are rejected. If all quality control
requirements are not met, it is required that the data is qualified and the
qualification appears on the back of the Discharge Monitoring Report (DMR).

age 5
Any rejection of data from the storets will be issued by the agency, which receives
the data.
The Quality Control requirements of the method are outlined below:
1. The DO depletion of the dilution water blank must not be more than 0.2 mg/l.
2. The seed controls must deplete at least 2.0 mg/1 DO and have at least 1.0 mg/l
DO remaining.
3. The samples must also deplete at least 2.0 mg/l DO and have at least 1.0 mg/l
DO remaining.
4. No evidence of toxicity should be present. This can only be evident when at
least three dilutions are analyzed. This is characterized by an increasing BOD
value as the sample concentration decreases.
5. The glucose glutamic acid standard must be in the acceptable range of 198 mg/1
+ 30.5 mg/l.
6. The seed correction, calculated from the seed controls, must be between 0.6
and 1.0 mg/l.
Anytime any of the above quality control requirements are not met, the data must be
qualified. The qualifying statement should indicate how QC requirements were not met
and indicate whether the data is valid. But the data must always be reported.
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory bench sheets
and contract lab reports to DMRs submitted to this Division. Data were reviewed for
these months: September, November 1999, and January 2000. No errors were noted. It
appears the facility is doing a good job of accurately transcribing data.
V. CONCLUSION:
We are concerned with the violation(s) that were cited previously and not corrected.
Failure to correct the violation(s) cited in this report will lead to enforcement
action.
Ref: 15A NCAC 2H .0807 (a) (1) and (14)
Laboratory Decertification:
A laboratory may be decertified for any or all parameters for up to one year for any
or all of the following infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or
quality control program as set forth in the application, and these Rules; or
(14) Failing to comply with any other terms, conditions, or requirements of this
Section or of a laboratory certification.
Correcting the above violations should help to produce quality data and meet
certification requirements. Implementing the recommendations will further improve
the quality of the data. Another inspection will be conducted in three to six
months.
Report prepared by: Gary Francies Date: 3/29/00

.� am NORTH CAROLINA DEPARTMENT
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
March 15, 1999
Mr. Jack A. Dellinger, PhD `
General Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina -28728
Subject: Performance Audit Inspection
( Inspection Rating IIS-Minus"
Wastewater Treatment Program
BASF Corporation -
NPDES Permit Number NC000.0299
, Buncombe County, North Carolina
Dear Mr. Dellinger:
The Performance Audit Inspection (PAI) that Gary
Francies and I conducted on February 18, 1999, of BASF',
wastewater treatment program resulted in an overall rating of
B-Minus relative to the evaluation of sampling, flow
.measurement, and.laboratory procedures. Regulatory and
methodology violations were identified in the laboratory
portion of the inspection which basically centered around
handling of chlorinated samples for ammonia and fecal
coliform analysis. Additionally, documentation of drying
times for the total suspended residue analysis together with
BOD seed correction and dilution problems need to be
addressed. Comparison of results of split sample analysis
between the BASF laboratory and the NCDENR Water Quality
laboratory show concerns which need to be further evaluated.
The results of this PAI should not be interpreted to
question compliance with terms and conditions contained in
the NPDES permit. Sample analysis showed the. discharge to be
meeting effluent limitations and the evaluation of the
wastewater treatment facility showed proper operation and
control. The high total suspended residue concentration
tentatively attributed to the presence of finishin oils in
the wastewater stream is of concern asit approache e
daily maximum effluent limitation. The source of the high
total suspended residue concentration should be located and
addressed.
INY........ SW LONO, SO WQ..11. 1.., A[N[VILL CNC 38801-341•
PNON[ 82e-3818308 FAX [phone]
AN EQUAL OPPORTUNITY 1APPIRMAT1VE A-1.a EMPLOYE....% RCCYCLEW10% I.., ...... PAP2P

PERFORMANCE AUDIT INSPECTION
WASTEWATER TREATMENT FACILITY (NC0000299)
BASF CORPORATION
ENKA, NORTH CAROLINA
FEBRUARY, 1999
INTRODUCTION
On Thursday, February 18, 1999, the North Carolina Division of -
Water Quality concl'iicted an on -site inspection of BASF's
wastewater treatment program including evaluation of the
laboratory and sample collection procedures.
The Performance Audit Work with the Company's laboratory was
conducted by Gary Francies and Max Haner of the Division's
Asheville Regional Office. Personnel from BASF Fibers were Ray L.
Ackerman, Manager, Environmental/Safety/Qualityand Operator in
Responsible Charge (ORC) of the wastewater treatment facility;
Kay Crowder, Maintenance Superintendent and backup operator; Don
Canine & Don Wilkey, electrician; Ross Peebles, laboratory; and
'Fric Barbour, iEe Facilities.
The purpose of this inspection was to determine the quality of r
the self -monitoring program being conducted by BASF Fibers
Corporation and assess the reliability of its reported data.
The inspection consisted of evaluation of the flow monitoring
equipment and data handling, evaluation of sample collection and
Preservation techniques and evaluation of laboratory and
analytical techniques, record keeping and data reporting
procedures. NPDES permit number NC0000299 provides for a
discharge (001) from the Company's wastewater treatment facility;
two equalization basins (series),an aeration basin, dual final
clarifiers, a chlorine contact chamber, a mixing lagoon, sludge
handling and disposal (thickener, conditioner, filter press, BASF
landfill as cover) with discharge to Hominy Creek, Class "C"
waters in the French Broad River Basin. Additionally, the permit
provides for a discharge (002) of non -contact cooling water from
a barometric condenser into Hominy Creek via the east ditch on
BASF property. -
BASF Fibers Corporation is conducting the self -monitoring part of
this program in accordance with monitoring requirements contained
in NPDES Permit Number N00000299. Flow measurement, composite
sampling and collection of samples is satisfactory. Violations
were found, however, with the laboratory methodology which
addressed sample preservati n (and documentation) for chlorinated
samples for ammonia and fecal cola orm analysis. Additional
violations were noted in documentation ofddr ing times. for total
suspended residue sample analysis and see 'or
c ion and
dilution practices in the SOD sample analysis. As resu t,
the overa P rating for this facility is B-Minus. A PAI.
rating sheet is attached.

Page 2
1999 PAI Report - - - - -
BASF Corporation Wastewater Treatment Facility
FINDINGS AND RECOMMENDATIONS
Recommendations contained in this -section ill appear as
regulatory requirements to correct deviations or as suggestions
to strengthen the self -monitoring and laboratory program.
A. FIELD EVALUATION
1.- FLOW MEASUREMENT: Flow is measured at the 001
discharge structure in the final mixing lagoon using a
30-inch cipolletti weir with a Miltronic ultrasonic
depth probe and Honeywell Recorder, Accuracy of this
unit including the integrity of the work is checked
weekly, The unit is checked for accuracy during zero
flow periods when the level of the final basin is
lowered for maintenance. Last calibration. by Law
Engineering on 1/28/99. A check of the weir showed it
to be plumb, level, and meeting requirements for a
properly installed cipolletti weir. Additionally,
instantaneous flow measurement at the weir compared
with instrumentation recordings showed a difference of
approximately 7.6&, well within the allowable 10%-
difference.
a. .RECORDS: Records are maintained in a hardbound
notebook by Don Canipe, maintenance (electrician).
Mr Canipe was assisted by Don Wilkey.
b. DATA HANDLING: Flow totalizer measurements are
handling properly.
2. SAMPLING PROCEDURES: The effluent composite
sampling device for discharge001 is an ISCO-model
371OR unit with refrigeration. The permit requires no
monitoring of discharge. 002.
a. Effluent 24 hours composite samples are collected
proportional to flow with a setting of 125 ml per
cycle. Each sampling cycle is approximately 5,000
gallons. Two separate measurements showed the actual
sample aliquot to be 124 ml and 120 ml.
b. Pump and sample tubing last was replaced in
October Tubing is checked routinely and
rep aced as necessary. The, sample strainer was in need
of cleaning.

Page 3
1999 PAI Report --
BASF Corporation Wastewater Treatment.Facility
C. Records: The volume of each composite sample is
measured and recorded. These records also should
include the temperature of each composite sample upon
collection.
3. FIELD MEASUREMENTS:
a. The effluent dissolved oxygen (D.O.) measurement
is measured daily during the time the composite
sample is collected for analysis using a D.O. meter
and probe. D.O. measurement of the discharge was
8.9 mg/1 Q 11° C (NCDWQ). -
b.. The effluent pH measurement is performed in the
laboratory from a grab sample collected from the
discharge during sample pickup. The PH was measured at
7.90 s.u. (NCDWQ).
C. The effluent total residual chlorine concentration
is measured is the laboratory from a grab sample
collected from the discharge during sample pickup.
The total residual chlorine was measured at 0.11 mg/1
(NCDWQ).
4. SAMPLE HANDLING: The composite sample (carboy)
was properly handling with the sample being thoroughly
mixed prior to transfer to the sample container(s).
5. RECORD MAINTENANCE: Preventative maintenance
work performed on the system was in accordance with
needs addressed in the weekly computer printout.
Calibration records for the dissolved oxygen sensors in
the aeration basin should be maintained. Time of
operation records for the solids handling system need
to be maintained.
6. OPERATION & MAINTENANCE: o&M is being performed
in a satisfactory with interest on preventative. The
south clarifier was being cleaned and its weir was
` being leveledduringthis inspection. Wasting of
solids based on F/M ratioand volatile solids in the
system (target 1100-1200 mg/1). -
7. PERMIT VERIFICATION: The facility is operating
in compliance with terms and conditions contained in
the NPDES permit (NC0000299). The permit accurately
reflects the existing wastewater treatment facility and
discharge location.

Page 4
1999 PAI Report
BASF Corporation Wastewater Treatment Facility
B. LA$ORATORY EVALUATION
1. PERSONNELL: All NPDES testing performed at this
facility is under supervision of Ray Ackerman. The manager
of the laboratory is Sack Dellinger, PhD.
2. FACILITIES AND EQUIPMENT: The laboratory is
spacious and adequately equipped for testing performed at
this location of this faciltiy. The laboratory routinely
conducts tests for pH, BOD, Total Suspended Residue, Fecal
Coliform, Ammonia, Zinc, Total Residual Chlorine, and
Temperature. The BASF laboratory is state certified for the
above parameters. Pace Laboratories, Inc., performs the
remaining NPDES analyses including Aquatic Toxicity.
A new spectrophotometer has been obtained by BASF since the
last inspection for ammonia analysis.
3. METHODOLOGY: All testing procedures are based upon
EPA's approved methodology or the Laboratory Certification
Regulation; 15A NCAC 2H.0800. Violations are entered as
follows:
a. Violation - Sample Preservation
Dechlorination of both the ammonia sample or the fecal
coliform sample is not documented and therefore
considered asnot being performed>
Requirement: 15A NCAC 2H.0805(a)(1)&(7)(M)&(N)
requires in part that samples containing chlorine, must
be dechlorinated at the time of sample collection and
treated according to the requirements of the anaklysis
to be performed. Upon receipt in the laboratory,
samples treated for chlorine must be checked and
documented to be free of chlorine.
b. Violation - Total Suspended Residue
The time that the sample is placed in the oven for
drying and the time that the sample is taken from the
oven is not being documented.
Requirement: 15A NCAC 2H.0805(a)(7)&(a)(7)(D)
requires drying times be documented.

Page 5
1999 PAI Report - -
BASF Corporation Wastewater Treatment Facility
C. Violation - BOD
The seed correction factor must be in the range of
0.6 mg/l to 1.0 mg/1: Records indicate the seed
correction factor for this analysis was below this
range.
Requirement: STANDARD METHODS, 18TH Edition, Method
52108.4d 2.
d. Violation - BOD
The dilutions used for seed control have been too low
to yield proper D.O. depletion and residual
requirements.
Requirement: STANDARD METHODS, 18TH Edition, Method
5210B.5 - requires that seed controls and samples must
have at least 2.0 mg/l D.O. depletion plus a residual
D.O. of 1.0 mg/1.
e. Violation - Method Quality Control requirements
not being met must be noted on the discharge monitoring
report-(DMR).
Requirement: 15A NCAC 2H.0805(a)(7)&(a)(7)(D)
4. RECORDS KEEPING:
Laboratory record keeping was consistent with good
laboratory practice. Records were complete and -well
detailed.
5. QUALITY CONTROL:
Effluent samples split with the BASF laboratory showed
the following comparison:
BASF LABORATORY DWQ LABORATORY
BODS 17.9 mg/l 26.2 mg/1
TSS 85 mg/1 102 mg/l
a
Non-eff leunt sample split only for comparative purposes
FECAL COLI 520/100 ml 270/100 ml

Page 6
1999 PAI Report
BASF Corporation. Wastewater Treatment Facility.
6. DATA HANDLING & REPORTING:
A review of discharge monitoring report (dmr) and
supporting data for August, October, and November,
1998, showed no data entry or dmr transfer problems.
The facility was transcribing data in a satisfactory
manner.

PAI RATING SCALE
Ratinc _ General Description
A The facility has no problems with flow monitoring,
sampling, analyses or data calculating and reporting
procedures. The overall self -monitoring program and
the quality and reliability of the data reported to
state/federal agencies are excellent. The general
operation of the entire facility is also very good.
The facility has a few minor problems in one or more
areas of flow monitoring, sampling, analyses or data
calculating and reporting procedures. Examples include
infrequent calibration of flow monitoring equipment,
improper refrigeration of samples, slight discrepancies
in oven or incubator temperatures and not keeping
thorough records. The self -monitoring program is good
and the problems have no major impact on data
reliability. The overall operation of the facility is
very good.
The facility hasa major or several minor problems with
flow monitoring, sampling, analyses or data calculating
and reporting procedures. Examples include
malfunctioning flow monitoring equipment, improper
sampling site, not dechlorinating fecal coliform samples,
unacceptable oxygen depletions and improper seed
correction factors in BOD analyses. The .problems noted
at the facility cause the reliability of some of the data
to be questionable. The general operation of the overall
facility is good.
There are major problems with flow monitoring, sampling
analyses or data calculating and reporting procedures.
Examples include estimating flow, collecting samples at
wrong locations, using improperglassware or equipment,
malfunctioning laboratory equipment, poor laboratory
techniques, or errors in data calculations. The problems
cause the reliability of the self -monitoring data to be
highly questionable. The overall operation of the
facility is fair.
Severe problemswithflow monitoring, sampling, analyses
or data calculating and reporting procedures cause the
self -monitoring data to be unreliable. Examples include
no flow monitoring capabilities, wrong sampling
frequencics and procedures, using unacceptable analytical
techniques or fabrication of information. The self -
monitoring program and the general operation of the
facility is poor.

a
M
de
6
„
R
n
9
r�
e
A
4
p
$
Saq
e
€
b
C
E
F
a
a
'az
c
N
E
ro
3
4
a
b
E
Rpg
a
O
m
m
y
A
O
A
z
a
m
z
K
i
6
n
m
a
i
0
x
K
`
m
�

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
March 17, 2000
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jack A. Dellinger, PhD
General Manager
BASF CORPORATION
Sand Hill Road
Enka, North Carolina 28728
SUBJECT: Notice of Violation and Assessment
of Civil Penalty for Violations of N.C.
General Statute 143-215.1(a)(6)
and NPDES Permit NC0000299
\\�l) BASF CORPORATION
Case No. LV 00-086
Buncombe County
Dear Mr. Dellinger:
This letter transmits a Notice of Violation and assessment of civil penalty in
the amount of 323.11 ($250.00 civil penalty + $ 73.11 enforcement costs)
against BASF Corporation.
This assessment is based upon the following facts: a review has been
conducted of the discharge monitoring report (DMR) submitted by BASF
Corporation for the month of December, 1999. This review has shown the
subject facility to be in violation of the discharge limitations and/or monitoring
requirements found in NPDES Permit NC0000299. The violations, which occurred
in December, 1999 are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that BASF
Corporation violated the terms, conditions or requirements of NPDES Permit
NC0000299 and N.C.G.S. 143-215.1(a)(6) in the manner and extent shown in
Attachment A. A civil penalty of not more than twenty-five thousand dollars
($25,000.00), in accordance with the maximums established by N.C.G.S. 143-
215.1(a)(2), may be assessed against a person who violates the terms,
conditions or requirements of a permit required by N.C.G.S. 143-215.1(a _ .....
INTERCHANGE BUILDING, 68 WOODFIN PLACE, ASHEVILLE, NORTH CAROLINA 26R01-2414
PNONL B2R-261-6208 FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 60% .Ec ED/10% POST CONSUMER PAPER

Based upon the above findings of fact and conclusions of law, and in
accordance with authority provided by the Secretary of the Department of
Environment and Natural Resources and the Director of the Division of Water
Quality, I, Forrest R. Westall, Division of Water Quality Regional Supervisor for the
Asheville Region, hereby make the following civil penalty assessment against
BASF Corporation:
$ -0- For 1 of the 1 violation of G.S. 143-
215. 1 (a)(6) and NPDES Permit No.
NC0000299, by discharging waste into the
waters of the State in violation of permit
monthly average effluent limits for TSS
$ 250.00 For 1 of the 1 violation of G.S. 143-
215.1(a)(6) and NPDES Permit No.
NC0000299, by discharging waste into the
waters of the State in violation of permit daily
maximum effluent limit for TSS
$ 250.00 TOTAL CIVIL PENALTY, which is 1.0%
percent of the maximum penalty authorized
by G.S. 143- 215.6A
$ 73.11 Enforcement costs.
$ 323.11 TOTAL AMOUNT DUE
-8-

Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I
have taken into account the Findings of Fact and Conclusions of Law and the
factors set forth at G.S. 14313-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State,
to the public health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air
quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by non-compliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with
programs over which the Environmental Management Commission
has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
Submit payment of the penalty:
Payment should be made directly to the order of the Department of
Environment and Natural Resources (do not include waiver form).
Payment of the penalty will not foreclose further enforcement action
for any continuing or new violation(s). Please submit payment to the
attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
KM
2. Submit a written request for remission or mitigation including a detailed
-9-

2. Submit a written request for remission or mitigation including a detailed
justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper
procedure for contesting the accuracy of any of the statements
contained in the assessment letter. Because a remission request
forecloses the option of an administrative hearing, such a request
must be accompanied by a waiver of your right to an administrative
hearing and a stipulation that there are no factual or legal issues in
dispute. You must execute and return to this office the attached
waiver and stipulation form and a detailed statement, which you
believe establishes whether:
(a) one or more of the civil penalty assessment factors in
G.S. 143B-282.1(b) was wrongfully applied to the
detriment of the petitioner;
(b) the violator promptly abated continuing environmental
damage resulting from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any
previous violations;
(a) payment of the civil penalty will prevent payment for
the remaining necessary remedial actions.
Please submit this information to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for
remission must be submitted in writing. The Director of the Division
of Water Quality will review the information during a bimonthly
enforcement conference and inform you of his decision in the matter
of the remission request. His response will provide details regarding
case status, directions for payment and provision for further appeal
of the penalty to the Environmental Management Commission's
-10-

Committee on Civil Penalty Remissions. Please be advised that the
Committee cannot consider information that was not part of the
original remission request considered by the Director and therefore,
it is very important that you prepare a complete and thorough
statement in support of your request for remission.
W
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you
must request an administrative hearing. This request must be in the
form of a written petition to the Office of Administrative Hearings and
must conform to Chapter 150B of the North Carolina General
Statutes. You must File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
Mr. Dan McLawhorn, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Failure to exercise one of the options above within th v days, as
evidenced by a date stamp (not a postmark) indicating when we
received your response, will result in this matter being referred to the
Attorney General's Office with a request to initiate a civil action to
collect the penalty.
Please be advised that any continuing violation(s) may be the subject of a
new enforcement action, including an additional penalty. If you have any
questions about this civil penalty assessment, please contact Mr. Max L. Haner of
the Asheville Regional Office at 828/251-6208.
-11-

Cm')
3 i7 Dd
(Date) Forrest R. Westall
Water Quality Regional Supervisor
Asheville Region
Division of Water Quality
ATTACHMENTS
cc: Max L. Haner w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
-12-

ATTACHMENT A
ENTITY
NPDES Number NC0000299
Case Number LV 00-086
Limit Violations, December, 1999
Monthly Average Limit Violations
Parameter Reported Value Limit Units
TSS 242.6 209.0 -#/Day
Daily Maximum Limit Violations
Parameter Date Reported Value Limit Units
TSS 12-15-99 701.0 565.0 #/Day
Effluent Monitoring Violations, December, 1999
Required Monitoring
Parameter Monitoring Frequency Location
insufficient Values
Parameter Date Number of Insufficient Values
-3-

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
-
COUNTY OF BUNCOMBE -
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
BASF CORPORATION ) STIPULATION OF FACTS
PERMIT NO. NC0000299 ) FILE NO. LV 00-086
Having been assessed civil penalties totaling $323.11 for
violation(s) as set forth in the assessment document of the Division
of Water Quality dated March 17, 2000, the undersigned, desiring to
seek remission of the civil penalties, does hereby waive the right to
an administrative hearing in the above -stated matter and does
stipulate that the facts are as alleged in the assessment document.
This the day of , 2000.
FE7
TELEPHONE

DIVISION;`) WATER QUALITY - CIVIL PENALT'1$ESSMENT
Violator: BASF CORPORATION rr
County: BUNCOMBE
Case Number: LV 00-086
ASSESSMENT FACTORS
1) The degree e�nd extent of harm to the natural resources of the State, to the
public heyith, or to private property resulting from the violation;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
2) The durat n and gravity of the violation;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
3) The sffec on ground or surface water quantity or quality or on air quality;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
4) The coat o rectifying the damage;
not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
5) The amount of money saved by non-c liance;
( ) not significant ( moderately significant ( ) significant
( ) very significant ( ) extremely significant
6) Whether the iolation was committed willfully or intentionally;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
7) The prior record of the violator in complying or failing to comply with programs
over whic a Environmental Management Commission has regulatory authority, and
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
8) The cost the State of the enforcement procedures.
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) ex r// l sign
if'cant
3
117,10 Date F feet R. Wastall, Water -Quality Supervisor
eheville Regional Office
REMISSION FACTORS
( ) Whether one or more of the civil penalty assessment factors were wrongly applied
to the detriment of the petitioner;
( ) Whether the violator promptly abated continuing environmental damage resulting
from the violation,
( ) Whether the violation was inadvertent or a result of an accident;
( ) Whether the violator had been assessed civil penalties for any previous
violations, and
( ) Whether payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Kerr T.Stevens, Director
Division of Water Quality

(� DMR REVIEW RECORD
Facility: BASF CORPORATION Permit/Pipe No.: NC0000299 Month/Year: 12/99
Monthly Average Violations
Parameter Permit Limit DMR Value % Over Limit
TSS 209 #/Day 242.6 #/Day 16.1 %
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value %OverLimit
12-15-99 TSS 565.0 #/Day/ Daily Max 7014/Day 24.1%
Monitoring
Frequency Violations
Date
Parameter
Permit Frequency
Values Reported
4
of
Violations
Other Violations
Completed by: Max L. Haner Date: March 16, 2000
-4-

DMR REVIEW RECORD
Facility: BASF CORPORATION Permit/Pipe No.: NC0000299 Month/Year: 12/99
Monthly Average Violations
Parameter Permit Limit DMR Value % Over Limit
TSS 209 #/Day 242.6 #/Day 16.1 %
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value %OverLimit
12-15-99 TSS 565.0 #/Day/ Daily Max 701#/Day 24.1%
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported # of
Violations
Other Violations
Completed by: Max L. Haner Date: March 16, 2000
-5-

LAW
LAWGIBB Group Member
February 2, 2000
Mr. Kay Crowder
BASF Corporation
Sand Hill Road
Enka. North Carolina 28728
Subject: Wastewater Treatment System Effluent Discharge Weir Calibration Confirmation
BASF Corporation
Enka, North Carolina
LAW Project 30300-0-0656
Dear Mr. Crowder:
Law Engineering and Environmental Services, Inc. (LAW) is pleased to submit this report of our
assessment of the effluent flow, measuring device used at your Enka facility. The purpose of our
services, as described in the attached report, was to observe the method of flow measurement and
equipment calibration for the wastewater treatment system discharge weir. Based on our
observations and calculations, the calibration method used by BASF appears to be complete and
accurate.
We appreciate the opportunity to provide our professional services on this project. Please contact
us at [phone] if any questions arise or if we may be of further service.
Sincerely,
LAW ENGINEERING AND ENVIRONMENTAL SERVICES, INC.
L+),,ua UJar
Matthew E. Wallace, P.E. David Wallace, P.E.
Senior Engineer Principal Water Resources Engineer VAMKRMISSION
Registered. NC #24933 Registered, NC #20055
MEW/JDW:mew
attachment
IAW Engineering and Emmonmemal Services. Inc.
1308 C Patton Avenue
Asheville, NC 28806
828 252-8130 • Fax [phone]

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
RAY ACKERMAN
BASF CORPORATION ENKA PLANT
SAND HILL ROAD
ENKA, NC 28728
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
August 26, 1999
SUBJECT: Revised Whole Effluent Toxicity Enforcement Policy
Effluent Toxicity Testing
NPDES Permit No. NC0000299
BUNCOMBE County
RAY ACKERMAN:
Based on recent discussions with EPA Region IV, the Division of Water Quality (DWQ) is further
modifying its Whole Effluent Toxicity (WET) Enforcement Policy. The primary difference will be
separation of DWQ's application of civil penalties from compliance determinations. Any WET test result
that does not achieve compliance with the NPDES permit limit will be considered a violation of the
permit and the pennittee will be sent, at minimum, a Notice of Violation. The Division's new Whole
Effluent Toxicity Enforcement Policy will apply to whole effluent toxicity monitoring initiated on
or after September 1, 1999.
Draft NPDES permits sent to public notice after 7/1/99 will contain chronic toxicity test condition
language which specifies follow-up multiple concentration toxicity testing upon any single quarterly test
failure. The first test of the quarter (three-month monitoring period defined by the permit) may be
conducted either as either a pass/fail test or as a multiple concentration (ChV) test If the pass/fail test
fails or if the chronic value is lower than the permit limit, then a NOV is issued and at least two multiple
concentration tests (one per month) are required over the following two months. NOVs will be generated
for each failure to meet the permit limit. As many analyses as can be completed timing the quarter will be
accepted. -
Permittees with NPDES permits which contain `old" chronic toxicity pass/fail testing language will have
the OPTION to respond to any single quarterly toxicity test failure with follow-up multiple concentration
toxicity testing or single concentration toxicity testing. The enclosed toxicity test condition language will
be incorporated in the NPDES permit upon permit renewal and/or permit modification. Initiation of
multiple concentration toxicity testing after any single quarterly failure will influence the Division's
enforcement response. Perndttees will be issued a NOV for any test result that does not achieve
compliance with the permit limit. A civil penalty will be assessed for each Qua rter of toxicity
noncompliance based on the arithmetic average of ChV s submitted for the remaining two months of the
quarter.
C',-,
t)
Musing Address; Telephone[phone] Location:
1621 Mail Service Center Fax [phone] Reedy Creek Road
Raleigh, NC 21699-1621 State Courier k52-01-00 Raleigh, NC 27699-1621
An Equal OpWitunily Affirmative Action Employer 50%racycleNl0% post avnaumer paper

Important WET Enforcement Policy items are:
• The first test of the quarter can be conducted as either a pass/fail test or a
chronic value (ChV) test.
• If the pass/fail test fails or if the ChV is lower than the limit, then a NOV is
issued and at least two ChV tests (one per month) will be conducted over the
following two months. As many analyses as can be completed will be
accepted.
• A NOV will be issued for any test result failing to meet the permit limit.
• Any civil penalty assessed will be based on performance over a quarter.
• NPDES Permits containing chronic toxicity pass/fail testing will be modified
upon permit renewal to include the new permit language.
II. ACUTE TOXICITY TESTING
• A NOV will be issued for each acute limit violation.
• A civil penalty will be assessed for any two consecutive acute limit
violations.
Note that no changes have occurred in DWQ's enforcement responses to acute limit noncompliances
since the May 13' mailing.
Choosing to respond to a chronic "fail' result with a pass/fail test instead of conducting multiple
concentration toxicity testing during the second and third months of the calendar quarter will
result in enforcement for single concentration test results which do not meet chronic toxicity
permit limitations.
As in the past, if you are unable to consistently comply with your toxicity permit limitation, you may
notify your respective Regional Office to discuss the possibility of entering into a Special Order by
Consent (SOC). The SOC provides conditional compliance for permit parameters that the facility can not
consistently comply with and may be issued in situations where facility operation and maintenance are
not in question. If a SOC is signed by the permittee/DWQ and contains toxicity as a noncompliant
parameter, you will be required to: conduct a Toxicity Reduction Evaluation (TRE), submit quarterly
TRH progress reports, and reduce/eliminate effluent toxicants to acceptable levels.
Additional explanation ofkey WET enforcement initiatives can be located on the Division's Aquatic
Toxicology Unit web page at http://esb.ehm.state.nc.us/ATU.html.
If you have any questions, please contact me or Mr. Kevin Bowden at [phone].
Sincerely,
7n Cat
Matt Matthews, Supervisor
Aquatic Toxicology Unit
cc: Regional Office Supervisor, ARO
Facility Files
Central Files
Enclosure

rRd93Y8'6$tmtlM&4
NORTH'
CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
March 7, 2000
239
MR. RAY ACKERMAN
BASF CORP - FIBERS DIV
SAND HILL ROAD
ENKA, NC 28728
SUBJECT: Wastewater/Groundwater Laboratory Certification
Dear Mr. Ackerman:
Enclosed are inspection checklists to be used for the
upcoming inspection scheduled for March 23, 2000, at approximately
8:45 A.M. Excluding the data review sections and any sections that
specify they are to be completed by the auditor, please complete
or have your analysts complete, each checklist. Any checklists for
parameters that no samples have been analyzed since the last
inspection do not need to be filled out. Any checklists that your
laboratory are unable to complete, or any specific items that. you
do not understand, will be completed during the inspection.
Please submit the original checklists to the inspector(s) on
the first day of the inspection. Copies are not acceptable.
Contact us at 828/251-6208 ext. 285 if you have any
questions.
/si�ncerelyy,
l.7 o-/y / /Ld ? c-, Ir
Gary.Francies
Laboratory Section
Enclosures
cc: Marily Deaver
James W. Me er
INTERCHANGE BUILDING, 88 WOODFIN PLACE, ASHEVILLE, NORTH
P XG1b20CRpFAXAR22RR-BEOR1I -2g19
AN EQUAL OanoaiuNlTV / AFFIRMATIVE ACTION EMPLOYER - 60% RECYCLED/109POST-DGN¢UMER PAPER

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
February 10, 2000
RAY ACKERMAN
BASF CORPORATION
SAND HILL ROAD
ENKA, NC 28728
• ae
��,. M
NCDENR
FFD I i X)II0
Subject: Renewal of NPDES Permit NC0000299
ENKA PLANT
BUNCOMBE County
Dear Pernittee:
The subject permit expires on September 30, 2000. North Carolina Administrative Code (15A NCAC
211.0105(e)) requires that an application for permit renewal be (fled at least 180 days prior to expiration of the
current permit.
To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than
April 3, 2000. Failure to request renewal of the permit by this date will result in a civil assessment of at least
$250.00. Larger penalties may be assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after September 30, 2000 (or if continuation of the permit is
desired), the current permit must be renewed. Operation of wastewater treatment works or continuation of
discharge after September 30, 2000 would violate North Carolina General Statute 143-215.1 and could result in
assessment of civil penalties of up to $25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact Robert
Farmer of the Division's Compliance Enforcement Unit at [phone], extension 531. You may also contact
the Asheville Regional Office at [phone] to begin the rescission process.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must
submit with the permit renewal application. If you have any questions, please contact me. My telephone
number, fax number and E-mail! address are listed at the bottom of this page.
Sincerely,
�'
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
Asheville Regional Office, Water Quality Section
NPDES File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919733-5083, extension 511 (fax)91973307i9
VISIT us ONIHE isTexrver®hUx//h2o.enr.slat000cs1NPDES [e-mail]

rl
NPDES Permit NC0000299
BASF CORPORATION
BUNCOMBE County
The following items are REQUIRED for all renewal packages:
❑ A cover letter requesting renewal of the permit and documenting any changes at the
facility since issuance of the last permit. Submit one signed original and two copies.
❑ The completed application form (copy attached), signed by the permittee or an Authorized
Representative. Submit one signed original and two copies.
❑ If an Authorized Representative (see Part II.B.I Lb of the existing NPDES permit) prepares
the renewal package, written documentation must be provided showing the authority
delegated to the Authorized Representative.
❑ A narrative description of the sludge management plan for the facility. Describe how
sludge (or other solids) generated during wastewater treatment are handled and
disposed. If your facility has no such plan (or the permitted facility does not generate
any solids), explain this in writing. Submit one signed original and two copies.
The following items must be submitted ONLY by Industrial facilities
discharging process wastewater:
❑ Industrial facilities classified as Primary Industries (see Appendix A to Title 40 of the
Code of Federal Regulations, Part 122) must submit a Priority Pollutant Analysis (PPA) in
accordance with 40 CFR Part 122.21. If the PPA is not completed within one week of
April 3, 2000, submit the application package without the PPA. Submit the PPA as soon
as possible after April 3, 2000.
The above requirement does NOT apply to municipal or non -industrial
facilities.
TTTTectititiitititi
PLEASE NOTE:
Due to a change in fees effective January 1, 1999, there is no renewal fee
required with your application package.
TTTrrrrrrrrTTT
Send the completed renewal package to:
Mr. Charles H. Weaver, Jr.
NC DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
Enka, NC 28728
A�}"�,
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RE50Urictk5
August 2, 1999
Subject: Payment Acknowledgment
Civil Penalty Assessment
NPDES Permit Number NC0000299
BASF Corporation
Buncombe County
Case Number LV 99-232
Dear Mr. Dellinger:
This letter is to acknowledge receipt of check No. 4095954 in the amount of $323.11
received from you on July 15, 1999.
This payment satisfies in full the civil assessment levied against BASF Corporation and this
case has been closed. Payment of this penalty in no way precludes future action by this Division for
additional violations of the NPDES Permit.
If you have any questions, please feel free to contact Vanessa Manuel at [phone],
extension 532.
i
Lent
ComplianUnit
cc; Raleigh Regional Office
Enforcement/Compliance Files
Central Files
1617 Mail Service Center, Raleigh, N.C. 27699-1617 Telephone [phone] FAX [phone]
An. Equal Opportunity Affirmative Action Employer 50% recycled/ 10% postconsumer paper

�-� NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
June 25, 1999
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
SUBJECT: Notice of Violation and Assessment
of Civil Penalty for Violations of N.C.
General Statute 143-215.1(a)(6)
and NPDES Permit NC0000299
J 9
BASF Corporation
Case No. LV 99-232
Buncombe County
Dear Mr. Dellinger
This letter transmits a Notice of Violation and assessment of civil penalty
in the amount of $ 323.11. ($250.00 civil penalty + $ 73.11 enforcement costs)
against BASF Corporation.
This assessment is based upon the following facts: a review has been
conducted of the discharge monitoring report (DMR) submitted by BASF
Corporation for Total Suspended Residue for the month of March, 1999. This
review has shown the subject facility to be in violation of the discharge
limitations and/or monitoring requirements found in NPDES Permit NC0000299.
The violations which occurred in March, 1999 are summarized in Attachment A
to this letter.
Based upon the above facts, I conclude as a matter of law that BASF
Corporation violated the terms, conditions or requirements of NPDES Permit
NC0000299 and N.C.G.S. 143-215.1(a)(6) in the manner and extent shown in
Attachment A. Pursuant to N.C.G.S. 143-215.6A(a)(2), a civil penalty of not
more than ten thousand dollars ($10,000.00) may be assessed against a
person who violates the terms, conditions or requirements of a permit required
INTERCHANGE BUILDING, 8B WOODF,N PLACE, ASHEVILLE, NC 28801-2414
P HONe9... GB'-82oe FAX B2B-2E1.848E
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 8G% RECYCLED/10% POST CONSUMER PAPER

Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural
Resources and the Director of the Division of Water Quality, I, Forrest R. Westall, Division of
Water Quality Regional Supervisor for the Asheville Region, hereby make the following civil
penalty assessment against BASF Corporation
$ -0-
For 1 of the 1 violation of G.S. 143-215.1(a)(6) and
ES NPDPermit No. NC0000299, by discharging waste
into the waters of the State in violation of permit
monthly average effluent limits for Total Suspended
Residue.
$ 250.00
For 1 of the 1 violations of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0000299, by discharging waste
into the waters of the State in violation of permit daily
maximum effluent limits for Total Suspended Residue .
$ -0-
For 1 of the 1 violations of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0000299, by discharging waste
into the waters of the State in violation of permit daily
maximum effluent limits for Fecal Coliform .
$ 250.00
TOTAL CIVIL PENALTY, which is 0.83% percent of the
maximum penalty authorized by G.S. 143- 215.6A.
$ 73.11
Enforcement costs.
$ 323.11
TOTAL AMOUNT DUE
-2-

Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S.
143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the
public health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by non-compliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory
authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty
will not foreclose further enforcement action for any continuing or new
violation(s). Please submit payment to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535
OR
2. Submit a written request for remission or mitigation including a
detailed justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure for
contesting the accuracy of any of the statements contained in the assessment
letter. Because a remission request forecloses the option of an administrative
-3-

hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues
in dispute. You must execute and return to this office the attached waiver and
stipulation form and a detailed statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-262.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting
from the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0636
Please note that ALL information presented in support of a request for remission
must be submitted in writing. The Director of the Division of Water Quality will
review the information during a bimonthly enforcement conference and inform
you of his decision in the matter of the remission request. His response will
provide details regarding case status, directions for payment and provision for
further appeal of the penalty to the Environmental Management Commission's
Committee on Civil Penalty Remissions. Please be advised that the Committee
cannot consider information_ that was not part of the original remission request
considered by the Director and therefore, it is very important that you prepare a
complete and thorough statement in support of your request for remission.
Ra
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an
administrative hearing. This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 150B of the North
Carolina General Statutes. You must File your original petition with the
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
-4-

n
and
Mail or hand -deliver a copy of the petition to
Mr. Dan McLawhorn, General Counsel
Department of Environment and Natural Resources
P.O. Box 27687
Raleigh, North Carolina 27611-7687
Failure to exercise one of the options above within the days, as evidenced by a date
stamp (not a postmark) indicating when we received your response, will result in this matter
being referred to the Attorney General's Office with a request to initiate a civil action to collect
the penalty.
Please be advised that any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty. If you have any questions about this civil
penalty assessment, please contact Mr. Max L. Haner of the Asheville Regional Office at
828/251-6208.
S
(Da )
ATTACHMENTS
nest R.Vestal]
Water Quality Regional Supervisor
Asheville Region
Division of Water Quality
cc: Max L. Haner w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
-5-

STATE OF NORTH CAROLINA
COUNTY OF BUNCOMBE
IN THE MATTER OF ASSESSMENT )
OF CIVIL PENALTIES AGAINST )
BASF CORPORATION )
PERMIT NO. NC0000299 )
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. LV 99 - 232
Having been assessed civil penalties totaling $323.11 for
violation(s) as set forth in the assessment document of the
Division of Water Quality dated June 25, 1999, the undersigned,
desiring to seek remission of the civil penalties, does hereby
waive the right to an administrative hearing in the above -stated
matter and does stipulate that the facts are as alleged in the
assessment document.
This the day of , 1999.
BY
ADDRESS
TELEPHONE

ATTACIRAENT A
ENTITY
NPDES Number NC0000299
Case Number IV 99-232
Limit Violations. MARCH, 1999
Monthly Average Limit Violations
Parameter Reported Value Limit Units
TSS 240 209 #/Day
Daily Maximum Limit Violations
Parameter Date Reported Value Limit Units
TSS 3/10/99 821 565 #/DAY
Fecal Coliform 3/23/99 510 400 Colonies/100 ml
Effluent Monitoring Violations, MARCH 1999
Required Monitoring
Parameter Monitoring Frequency Location
Insufficient Values
Parameter Date Number of
Insufficient values

DIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT
Violator: BASF CORPORATION
County: BUNCOMBE
Case Number: IV 99 - 232
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the
public he th, or to private property resulting from the violation;
(gnot significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
2) The dura on and gravity of the violation;
(-Olt significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
3) The effect on ground or surface water quantity or quality or on air
quality;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
4) The co.lf rectifying the damage;
(stnot significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
S) The amount of money saved byn-compliance;
( ) not significant ( moderately significant ( ) significant
( ) very significant ( ) extremely significant
6) Whether t e violation was committed willfully or intentionally;
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
7) The prior record of the violator in complying or failing to comply with
programs ov r which the Environmental Management Commission has regulatory
authority• and
( not significant ( ) moderately significant ( ) significant
( ) very significant ( ) extremely significant
S) The cost to the State of the enforcement procedures.
Date Fp'rest R�. W s Water Qua. ity Supervisor
ahe.A ville Regional Office
REMISSION FACTORS
( ) Whether one or more of the civil penalty assessment factors were wrongly
applied to the detriment of the petitioner;
( ) Whether the violator promptly abated continuing environmental damage
resulting from the violation;
( ) Whether the violation was inadvertent or a result of an accident;
( ) Whether the violator had been assessed civil penalties for any previous
violations; and
( ) Whether payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Date
Kerr T. Stevens, Director
Division of Water Quality

DMR REVIEW RECORD
Facility: BASF CORPORATION Permit/Pipe No.: NC0000299
Monthly Average Violations
Parameter Permit Limit DMR Value
Total Suspended Residue 209#/Dav 240#/Dav
Month/Year: 3 99
Over Limit
15 %
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value %Over Limit
3-10-99 TSS 565 #/Dav/Daily Max 821 #/Dav 45%
3-23-99 Fecal Coliform 400/100 ml/Daily Max 510/100 ml 28%
Monitoring Frequency Violations
Date Parameter Permit Frequency Values Reported # of Violations
Other Violations
Completed by: Max L. Haner Date: June 25 1999

AUG-23-1099 MON Ob:17 PM Of WATER QUALITY
a
FAX NO, 1A197339959 P,
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James S. Hunt, Jr., Governor
Wayne McDevitt, Secretary
KarrT. Stevens, Director
D E N R
Division of Water Quality
Environmental Sciences Branch
4401 Reedy Creek Road
Raleigh, N,C,27607
FAX:[phone]
FAX NUMBER:
FROM: mg 11155q
PHONE IloSP%rOCIL
NO.OF PAGES INCLUDING THIS SHEET: S
I-4

AUG-23-1999 MON 05:18 PM DL WATER QUALITY FAX NO. g197339059
P. 02
DIVISION OF ENVIRONMENTAL MANAGEMENT
July 8, 1994
MEMORAND[JM:
To:
Dave Goodrich
Through:
Matt Matthews Yuri "µp..�'
From:
MelissaRosebmcko
Subject:
Town of White Lake WWTP
Use of Rerbicide
NPDES No, NC0023353
Bladen County
On behalf of Town of White Lake W WTP, Michael Wicker has verbally requested that we
review the potential for aquatic toxicity regarding the proposed use of Sonar herbicide in the facility's
multi -cellular facultative lagoon. Mr. Wicker provided me with the appropriate herbicide name, .fWC,
minimum stream flow, NPDES number, and average daily discharge values. The Public Works
Director, Bill Stafford, provided data (through several phone conversations) conceming the proposed
dosage rate of the compound, lagoon surface area and depth, and retention time. I acquhed toxicity and
degradation data from the chemical manufacturer (SePRO Corp.) and Dr. Stratford Kay (aquatic weed
specialist at NCSU).
Mr. Stafford stated (phone conversation, 7/7/94) that the lagoon ranges from one to four feet
deep and that the entire lagoon is 4.42 acres in size. We have utilized an average depth of two feet in
calculating the volume of the lagoon. He also said that the lagoon would be treated only aroundits
perimeter at a frequency of once per month.
Calculations summarized on the accompanying worksheet predict that the use of SONAR
herbicide at the proposed dosage rate and discharge conditions will not result in a toxic impact to aquatic
life in the receiving stream. Therefore, the use of this product as a herbicide at Town of White Lake
W WTP is deemed a=ptable.
If there are questions regarding this review please contact me at (91.9) 733-2136.
Attaclunents
cc; Michacl Wickcr•IIRO
Steve Tedder
Central files

AUG-23-1999 MON 05:18 PM D� WATER QUALITY FAX N0, J.A�197339959 P. 03
Town of White Lake WWTP BIOCIDE WORKSHEET
PERMIT#: N00023353
RECEIVING STREAM: Colly Creek
7010 (cfs): 0.00
I.W.C. % : 100.00
PRODUCT:
SONAR A.S.
ACTIVEINGREDIENT:47.7%
fltlrldone
HALF LIFE (DAYS):
20.00
STEADY STATE DISC CONC:
0.0446
LC50 OF SELECTED TOX DATA (MGfL)'
8.18
DEGRADATION FACTOR:
0.243
DECAY RATE:
0.0345
APPLICATION FACTOR:
0.010
DOSAGE RAT E(GRAMS0AY):^
118.60
AVG DAILY DISCHARGE (MGD)'
0.6
INSTREAM BIOCIDECONG:
0.0448
VOLUME OF SYSTEM (MIL. GAL'S)::'**
2.88
REGULATED LIMITATION:
0.0818
IPASSIFAIL:
PASS
' Daphnis, 100% active formulation LC50=3.9, 47.7% active formulation LC50=8.18
"" 4.0 oz. of product added per day with a minimum retention lime of 3.94 days
4.42 acres X 2 ft. deep � 8.84 acre feet
8.64 acre feet X 43,560 sq. feet = 385.070.4 cubic feel
885,070.4 cubic feet X 7,46 (conversion factor) = 2,880,526.636 gallons
2,880,526.636 gallon$ = 2.88 millon gallons
Half-life (hours)
480
Shut Off time (hours)
94.56
Initial Amount
135.95
Final Amount
118.80

AUG-23-1999 MON 05:19 PM DIy, WATER QUALITY FAX NO. 1Q197339959
P. 04
Specimen Label
Se��O
11530 MOttp Meeidmin Street, sulk 200 4603x III�
Camel, ndi, ,,
P1,1oe:i3l7)6908292 Fm'io17)560Axs0
1\rSr
Sona //�+�",.
I'
Specialty Herbicide
A herbicide for management of
aquatic vegetation in freshwater
ponds, lakes, reservoirs, drainage
canals and irrigation canals.
Active ingredient:
flundone: 1-methyl-3-phenyl-5-[3-(trifluoromethyl)
phenyl]-4(11i pyridinone ..................... 41.7%
Inert Ingredients ....................................... 59.31/6
Total................................ ....... ...... ...-- ..... 100.0%
Contains 4 pounds active ingredient per gallon.
EPA Reg, No, 62719-124
EPA Est. 37429-GA-01
Net Contents 1 gal
Precautionary Statements
Hazards to Humans and Domestic Animals:
Keep Out of Reach of Children
CAUTION PRECAUCION:
Precaution al usuario: Sf used no lee ingles, no
use sale producto hssta quc la etiqueta le haya sido
axpticada ampliamente.
Harmful If Swallowed, Absorbed Through Skin,
Or If Inhaled
Avoid breathing of spray mist or contact with
skin, eyes or clothing. Wash thoroughly with
soap and water after handling. Wash exposed
,
clothing before reuse.
First Aid:
If In eyes: Flush oyes or skin with plenty of water.
Get medical attention if irritation persists.
If swallowed: Gall a physician or poison control
center, drink one or two glasses of water and induce
vomiting by touching back of throat with finger. Do
not induce vomiting or give anything by ri to an
unconscious person.
If Inhaled! Remove victim to fresh air. If not Oreath-
ing, give artificial respiration, preferably mouth-to-
mouth. Get medical attention.
Environmental Hazards
Follow use directions carefully so as to minimize
adverse effects on nontarget organisms. In order to
avoid impact on threatened or endangered aquatic
plant or animal species, users must consul[ their
State Fish and Gante Agency or the U.S. Fish and
Wildlife Service before making applications.
no not contaminate water when disposing of equip-
mont washwaters. Trees and shrubs growing in
water treated with Sonar A.S. may occasionally
develop chlorosis. Do not apply in tidewater/brack-
ish water.'
Lowest rates should be used in shallow areas where
the water depth is considerably less than the aver-
age depth of the entire treatment site, for example,
shallow shoreline areas.
Notice: Read the entire label before using. Use
only according to label directions. before buying
or using this product, read "Warranty
Disclaimer" and "Limitation of Remedies" else-
where on this label.
In case of emergency endangering health or the
environment involving this product, call collect 517-
636-4400
Specialty Chemical; Keep away from food, feed -
stuffs and water supplies, Do notshiporstore with
food, feeds, drugs or clothing.

AUG-23-1999 MON 05:19 PM '( WATER QUALITY
FAX NO. ' 0' 97339959 P. 05
t
vascular Aquatic Plants Not Controlled by Sonar
A.S.:
Algae (Chara and Nitella)"
Amerman Irogbit (Limnoblum spool
Arrowhead (Srplferlaepp.)
Hacopa(Sacooa spp.)
Big floa inghean, Banana Lily (NymphOW08 anUadca)
Bulrush (Screpus ,pp,)
Floating waterhyadnth (E(chhomie crasslpes)
Mafdencano (Ponicum hemilomon)
oickcielweed, lanceleaf (Ponledarla Cordaro)
Rush (Juncus sop.)
Tapegrass, America,) Seloeos6 (✓olllsnona anwrictl
Walerlettuce (Pisila stealiotei
Water pennywort (Hydrocafyte umbadata)
Mixing and Application Directions
The aquatic plants present in the treatment site should be oenhfied
prior to applica tic to date rmine their suscaplii it try to Sonar A.S. It is
important to determine the area (acres) to be treated and the average
depth in order to selact inn proper application rate. Do not exceed the `'
maximumlabeled rate (or a given inialmentsite perannualgrowth `.
cycle.
Shake Sonar A.S. well before using. Add the recommended amount
of Sonar A.S. to water in the spray tank during the lilting cperaron,
Agitate while filing and during spraying. Surface or subsurface applica-
tion al the apray can be made wish conV e n Bonet spray equipment.
Sonar A.S. can also be applied near the sadists al the hydr adl using
weighted trailing hases.''A pray volume of S to 100 gallons per acre ,
may be used; Sonar A.S.' may also be diluted with water and the Con- n
captioned mix metered into Its pumping system. b
Application to Ponds
Sonar A.S. may be applied to the entire surface area of a pond. Rates
may be salncled to provide 0.06 to 0.0,g ppm of active ingredient in the
treated water,, Application rates necessary to obtain these active ingfe-
arenl concen ualions in true led water era shown in the fallowing table,
When average water depth of the treatment site Is greater than 5 fool, y
apply 1 to 1.5 quarts of Sohdr A.S. nor treated surace acts:
Average Water Depth
of Treatment Site (122,l
quarts of Sonar A.S. per
Treated Surface Acre
1
0.16-0,25
2
0.33.0.50
3
0.50.075
4
0.65. 1.00
5
0.60. 1.25
Use the higher rate within the rala range where there is a dense weed
mesa of when fronting more di Nieult to control spades.
Application to Lakes and Reservoirs
For best results In lakes and reservoirs, Sonar A.S, treatment areas
should be a minimum of 5 arms in size Troatment of areas smaller
thrill 5 acres or tresintent of narrow drips such as boat lanes or ehore-
1 ass may net produce data factory resul is due to ditu lion by on bested
water. In lakes and reservoirs, do nqt apply Sonar AS, within antl;
foudh Mile (1a2a fedt7 of any functioning"potable water rrh&O4;
Rates maybe selected to provide 0.075 to CAB firm of active ingredi-
ent in the treated water. Application rates necessary to obtain these
active Ingredient concentrations in treated wmou are shown in the fol-
lowing table. When average water depth of the Ifeatment site is groatol'
than 10 feel. apply 3 to 4 quarts of Sonar A.S. per treated surface acre.
Average Water Depth
of Treatment Site Feet
quarts of Sonar A.S. per
Treated Surface Acre
1
02-0.4
2
0.4 on
3
0.6-1.2
4
0.0.16
5
1,0-20
6
1,2-2 4
7
14.2.6
6
L5-32
9
10.36
10
2.0.4.0 .WJ
Use the higher tale within the rain tango whore more is a dense weed
mass or when treating more difficult In control epgi
Application Rate Calculation - ponds, Lakes and
Reservoirs
The amount of Sonar A.S. to be applied to provide the desired ppm
Coneenlralion of active ingredient in treated water may be cdlcelated as
follows:
Quarts of Sonar A.S. required per Iroatorl amfaca acre - Averago
water depth of Irealment site (feet) x Desired prim concentration of
active ingredient x 2.7
For example, the quarts per acre of San at A.S. required to provide
a concentration Of 9,075 ppm of active Ingredient in walor with an
average depth of 5 feel is calculated a5 follows-
5 x 0.075 x 87 = to quail per treated surface acre.
Whaa measuring quantities of Sonar A.5-, quarts may bo cen-
verled to fluid ounces by mull iplyi ng It, and to be measured x 22.
For example, 0.25 quarts x 32 =. 6 fluid ounces.
" Notei'Calculated rates should not exceed lha mekhnunt allowable race
llh quarter p'a'rtrodtdd surface'acre'i&Pthe wale) d'eplti listed In the appll^1f
cation rate table for the site to be treated. l�
Application to Drainage Canals and Irrigation Canals
In drainage and irrigation canals, Sonar A S. should be applied at the
rate oft quarts par treated sudaee acre. Where water retention is for.
sible, the performance of Sonar A.S. will be enhanced by restricting
water flow. In moving bodies of water, use an application total that
will provide a uniform diae'ibution and avoid conkedlnallon of the thorn.
side.

AUG-23-1999 MON 05:20 PM DJ•S1, WATER QUALITY
FAX NO. 10197339959 P. 06
;Ut-!C-i994 1015E EEPPO CORPORATION
Asfive Ingredient
Chcntical Stnrcture:
0
N
CF; CN3
NomWLature;
1•itzttly'l•3•phenyb5-I-3 (tri:"Cb
rnmethyl) pl:enyll `(1H)•pylidinone
common No=
Fluneone
Molccuiar%Velghe
329.3
,4ppeaance;
Technical Curldone is a white to ea.a
en'srallme 50M,
]letting Point:
154.175' C
Vapor Pressure:
Less then 1 X 10' mm Hg at 25° C.
Flnridone is our4dered to be non-
,,latile and will not uaperate into the
almo-pl:em doling or niter appt)ing
sonar to eater.
Solubility In Rater;
12 ppm
Products
Sonar A,S,
Formulpliun Type;
aqueous sospens:on
Compositiow
Ilun )e: 41.1%
otherinpredienM 58.3%
'
(tlon:alrla 4 POLIL145 lctive ingrediulL
PC-.- gallon)
Solubility In Water:
disperes lcl water
Speci(t[ Grmiry;
1.15 at 23' C
appeprapce:
light•tan to Fray op, cquc liquid
Odor:
slight odor
Pl-I''
8.45 (agneuus 50150)
FIn5h Point:
greater than 200° F, 93T C (method
used — 5CC)
Volarility:
hnrvolatile
317 -`SC, =.=PE1 'r'. td7
Sonal SOP
Formulalim, rype: siow-t'elesse Pellet
Composition:
6uddone, 5,01"116
otSer inoradieuts: £)i o"'
(Contains T pounds acdee Inpatent
per io-po tmi container)
Solubility III l'w`ulerl
pellets d;cmt1rlIle irl Wahl'
Appearance:
dark-g:'ay to dark -broom pellet
odor:
F;intmuAy+:dor
pE
3.5 (aqueous 50h0)
Volatility:
. 11vola0.0
Made-oE-action
1'ne acthre ing%CdEnr In Sonar, tlsridone,'.nhNLS +, plalsz:a=il-
ity to make food. Wit}:aa that ,knlny, the Plant dies
jpecifically, I1F1rdone 111HOits CATotecoid s)n IIC515
(iarotenoids (yellow pigments) are ma intponaM pan of the
planB phutw)'c:hettc (food-n•.al'Mg) s)=.(ero. These ycl:av: pig;
meets protect the'dkts ('blorophyll (green pigments) Lo.n
decotmposition by sunlight, o'; phnmdegradedon, lVlaen
caroCenold synt!:esis is:nhibhe•,d, Chlorophyll becomes eapoaea
to photodegr'ada:im, and is g-adual+ry destroyed.
,As a plaetw th:utophy'll deerrses, so does its cdpaciry•:o pm-
ducc carbohydrptes through phntoslmthzsls. The t isaal s}mp•
tom aCfurdones activity in plan:S Is gra2.na1 cn':oro5is, which
develops on the'.errvinal bed or gnawing po ms of the p .nl.
Cnloro5i5 appeals 55 a bleec'nln; or whiunin� of PLUS due;o
cc
the absence or deEcierof green chlorophyll pgnaeots (planrs
become "whitish" or pink as they tore chdorouh)11).
It lakes 30 to 90 days For Sonar to C011=1 zsabl sdaed v: eedS.
'.ohhal herbicide symptoms appear a,cen to 10 d,a)s after applo-
ratton. Suscepmh':e plants absorb saner through shell' leaves
and 5ho6Ls and from the hy2sauil tda roots.

AUG-23-1999 MON 05:20 PM D111, WATER QUALITY
l
SOIJ-2D-7'394 10157 S'EPRO GORPORATf ON
FAX N0. j97330959
(
217 5:K E2EO P.CII
P. 07
Before application
Consider the follomng factors before using Sens, for 4dtlwiw
aquatic plant m irage.mtne
bumded water use. Trea[ments with Sonar should fit into
c:porly developed and defined wirer -manager mI ol;ccnves
:hat take into awn;mt the water bodys trended ones. N:n.ether
us cwaliining and boonng, fish or watericovt c,an;:,rn•.e:::. trot.
ia{ion or nzstne[ics, Poe weer body's in:girded ck; af;ect s
ty,aearid degreeofcomrolselecim4.heck thelate! for the
matt up�io�daw stntarrents rzgarding water uaa.
Time ojycar. For bear results, apply Sonar ir.,mediately bela;e
or during the early ocaea of the target plant's active growth.
sonar tray be applied when nontarg2t plants are dorinin, to
n:lrait)rte elects to these specter. Make appkiitions tci:en
water movement is at a mininrlinY, avoid penoda &song cr
.nimedtately of cr heavy rainfall to present diiudon as ita
untreated water.
Moving iaatt'i: Sonar A.S, is reeonniumcled for n,t in Wlller
Mill Gale movemcm (especially if plants are on tine surFzce). III
moving tuater, Sonar SRF (sluw•release pellet) works best. Split
rrtatn:@its niay increase the rrea[nier o's LLffeCdl'anass in muting
wafer by extending the htrbkide"� contact time with to gyp
w'aads. Restricting water Ilow, w'hec possiblemay airs
enhance ,ntrol. Rapid wirer movemrnt, ar any cundrron th'st
:apldly dllutes tuater heated w'iin Sonar, reduces C.&CU\cness.
Cse an applfeadon method Thar +prmieles untfnmt dsld'oution
pf hzrhicide in the treated avatar. Avoid Concentrating the
herbicide.
Area and d4a, cau'idernfitntS. Entire, ponds. may be «ea;cd al
one hme. When neadnglokes and ressn-o'irs, treanuen;areas
should be a minimr:m of five asrea in Size, TTeating areas
q,aller than live acres or treating narrow strips, may rear:!: in
unsansfac[ory results due to dilution with untreated uauer.
Rates necessary for effective control vary with tuater depth
Cheak the tables on page 5 as a guide.
Desirable vegetation. Sonar may be used to manage exe:ic
cpcie5, Spch ag hydrilla and Eurasian w'aterroilfotl, selerrvely.
with minimal effect on monp durable, nova plan!;. Spcaias
susceptibility can rah, depending on time o-year. mage of
growth and a'awr movement, Cmain aswb shed
trees, Stich as Cviriesi,'ar'a tn121ffi1L hV $Uttar
Government regulations. Alwoys wet', and follow product lahal
directions. Consult with ippropmte let a , at,.tc or federal
w'atarvgut'cTing.authodties]a�Pt+;e auplying mar In public
Waters. Sure or local public AgenJe's mlY lct uIte oermP
Application methods
Apply Sonar with :tpp'iccaucot 'nat prnt-.de5 cniform
application ova: ilie treated area Scner may be toed in cnn-
juneliun with other regstend agcalle herbicidal or algicides
Sonar,kS. offers three apil immn opiinn3: s.:rfnee-applird,
subsu dace-applfed, and bottom ape; lication piaecd along or
,lust a'lom C the hydriisoil, Spay-mlurae n-,ay vri '. L'at should
be sufficient for c1y application and sufficon� cove,rege.
Sonar SRP may he applied using equiprzra drst.;;ned for
spreading granules or pellets..App'y dre reco:n:nenaied imount
of Sonarpellets seer the roarer stmface unng'an dtrtrit pellet
spreader, a'olmccr Or n timed gcaeuiar app:icatol
Application precautions
Fe!'ore' 41ying Sonar, consult <.Cr,:e 5sh am✓rr gain ngencim
or the U S. Fish and Wildlife Seev;u to + d mpatltm,
threatened or endangered aqua Cc pant or animal species. Do
rot con[enenatz avatar braises L`y cleaning appaic�uon
equipment in corn or disposing of a�p'.I(`atlpn w'ostes in; o
them. noes and climbs gmw°at;!:r twzter u'z;;.ed tC.th Sotutr
may aceaalonaliy develop clrla:os!s_ Do no: apply Sonar to
tidewater or brackish water.
Application tatas
Dererminc the area (acres) end acQNAW winter depth of the
treatmont site before selmun- the propzr eppt;tatlon Este. Do
not exceed the maximum labeled rate for a yh'tn ;reatmettt site
per annual growth cycle. The tables on page 5 ciTide lhec
gener,i uae rates 'or Sonar A S and Sonar SRR. Consult the
product labels lot complete use metmetaans and prrecautiona.

AUG-23-1999 MOW 05:21 PM D(`,� WATER QUALITY
FAX N0. j97339959 P. 08
7UN-20—a?54 10!57 SFF'Pci Ct7RPGRAT I IN
Lakes & Resemirs
For best its -'as in s'Resand reFn-olrs, Sonartreamwm areas
should he a minimum of eve aces in size. Treating nancw
srnlas, sneh'aa laoat lancet or shorelines, may pnuluce unsads-
factory result; due to dilation with untreated water.
In lakes, ,,no rescn'olis, do not at Sonar within onedourrh
Mile (1,320 (eel) Of any ftmetfmning potable teeter intake,
Rates ma)he selected egaieaknUo adding 0.075 10 0.15 ppm
oFaetive ingredlen: to treated water. The following tablet shams
ine rates needed to achieve these active ingxdient equivalents.
Llse die lag::er rate'•Cithin the rate :an,t where there is a dense
+seed mass, or whet tnlating diffcalt-to-control species: (See
New York label for feces spedne m the Stare 1
Act. water allot, or i,,Aar SRv jm,,lea:ad Sonar A.S. per treated
n'zatraen: vv [it) surfrce ae:a I10 a_rl'au acre (,,u)
—..-. l ... --N Ih 0.4-0.8
0.9-16
—
_-._ zu-gin l.p-2o
s-6 1.4-as
—....._ r 32. 64 to-3.'_
J...-->l0 60-fill 3.0. i.3
"I'w
:taus;: rns hsa:''rr::<(:e,puaowrne::.nap nn::r d=r:6 a mrs:Gn:7y.'mnhen r. t.n.-.
eµt tertl•. e!'ky.: rre rn„*.,ev md_sR rel:re nerai
Application rare Calculation
When figuring applic❑tt0n rates for ponds, takes'and resenro(r.
calculate the,mean[ of product to apply per treated surface
acre to achlePa the desired ppm conc titration as follows:
Sonal SHP
pounds of SMV 5RP required per treated acre - Amn-a water
depth of treannent rite ((M) X Desired ppm Concentration of
active ingredient X 54
For enzmple, the pounds per acre of Sonar SRp required to
provide a concentration of 0,073 ppm of active Ingredient in
water with an average depth of 5 feet is calculated'as follows'.
5 X 0.0,75 X 54 = 20 pounds per treated surface acre
317 =Sell 7;^0 r.:il
Ponfls
sonar may be apnliad to tin mule surface area of a pond
5elee retes eonir,lent :o adding 0,06, to 0,09 ppm of active.
:rpradient to ecaced Crater. The folloring ta61e lists th:, rates
needed ro achieca these aCtjl-5rg7dient ec, :calems. Use lh:e
higher rate within the rase lunge Cohere there is a dense weed
mass, or when treating dif:icult•tp•[ontrol snecles. (<_ze Nett
1'oa: `abet for rnes spactfic to lard snug
9 Cedar depth of yarm'c!2P oar neared Sara i�. aer trea'<d
smummt Rile (IQ adra (''.h.0 ='a^a^-a c, r (4:=)
1 7.2'-" �d16.025
2 6.5 - 1U 033 050
;^ 10-13 050.073 ^_
.� 13 20� 005-1 00
>3 Z0. i0 100� 1 50
-u,, a., :c"I P:e to;rt
ae a.a
„s 1e>F1 a'A:e eagle i :n:vrn, ca 4 g.: ....,..,_i
Sonar A.S.
Quarts of Sonar A.S. requfreti par tremen acre = nvKrage ......
depth of treatment site (feet) X Desired ppm coucentrmtion of
active ingredient X 2.1
For example, the gaans per acre of Sonar A a. required to pro-
,18, a concern notion of 0075 ppnt of active ingre(llent In water
with'an average depth of 3 feet is ealcelz od es, follows:
5 X 0.013 X 2.7 = 1.0 quart per treated surface acre
Note:
1) Calculated application rates for Sonar A,5. and Sonar SNP
should not exceed the matimum anowahle mu, per meat ed sur-
face acre for the CC'ater depth, os listed In the tables above,
2) Split appiteationa using low rates ends certain conditions
may inerN25e treatment cascavene55. Do not exceed the mad-
nrtun labeled rate for a overt teattent site per amutal growth
cycle.

AUG-23-1999 MON 05 21 PM Dy WATER QUALITY
,
�7Whi-Fhl-'1994 LFl1 SE 4EPR0 CORPORRTION
Irrigation precautions
Chnnigntiorr
Leo not apply Sonar A.S. rhmugh any type of irritation SySlem
Irrigation
Irrigation «ith Scrar treated wafer may result in injury to the
irrigated vegetation. PnwElanco recommends Informing those
who Itr?gate from. Sonar treated araa3 of tha irrigation time
fnmee presented in the follo,eing table. These time frames are
suggestions that s1-.ould be followed ca reduce potential injury
[o irrigated vegera:tnn.
Saw SPP
Application isabl"shed Established raw
silo 1 cal crops crtromy,Upinnu
7 30 30
likes tV 7 7 7
tes"o: n
Diainage ditches, irrigation nanals & rivers
Either Sonar A.S. a: Sono; SRP may tie applied w drainage
canals and imgn:on canals (see icrtgtation precautions"). Sony
SRP may a1w be applied to rivers. Where water retention is
possible, restrict t:ater F.o„'to enhance nrocluct per(oml nce
Consider wing Sonar SRP where w, ter totmion is not posel.
ble, Whorl enply^.:.t Sonar :o MOVing watef, use an application
pattern thL; PI urdfo= c?'stributlon and avolds concan-
bating the rwi b'.cide in one area.
Split n'e'dtments, '�emg pomotK that do not exceed the
maximum !noei'n rrr.e nor annual gru,rth cycle may increase
trtatme0t eUeLin trust, (See New York label for ryes spvdfic to
the state )
Sonar 510Ir_ trcalucl Suns A.S. per rmawd
surrnce ees clhs) e'1M=Is- (gtsl
2
FAX
NO.
1.g197339959
P.
09
317 52L
Sonar A.S.
n_ys afro applltati
Appdu6on lrfe crops
Fstablcrops.
ishedrow
s,la rpS, @Yr/p!d:.6
7 31) 0
Lakrs & 7 14 1?
rwMoirs' I
9rdcdn a.nruaLn ¢"7rv�z.e.<,.,,
•orau7um knzr htt5¢,41:'rRlin6,nN:'a�e=fi,ad z<sp.]p etu,::r inrtma;'ei6.
scs.
'1116Nu a�:� `rv'uLl n�urc nnpW:!utrwlG'e!rh.t bMYof iklr9r'r l:eveA.us Cvyund en�l
s4lie:ni6rr%ram t1v!I:rr.

AUG-23-1099 MON 05:22 PM DLl WATER QUALITY
t )
SLIN-26-159c 1ril FS SEPRO IXIPPORRTION
FAX NO. ,;�97339959 P. 10
saa see aae�� P.©a
Atmospheric evaporation
Flundona, the ry nve ingredient in Sona- herbicides a consid-
ered to be nonvolatile, tvuh a vapor pT-ssure Iess thar. l X 1 OF
mill: never of mercury at 25° C. Therefcrc. autidone
evaporate tam the almospnem, during or after applying Sonar
to utter.
Water quality
Rdsenreh shoos inat treatments with Son- do no; appear .o
affect water chemistry o- water quilry adversely:
Researchers have t7cmvr¢d up io 23 dicerent uarameter in
numerous held experiments encuirtpasmtq a catitay of aquatic
enci-0lll`M4rn5, Treated w'atera ranged `nom aUlie to alkaline,
soft to very he.rc; and pure to almost sa!:re. These exoetimznts
showati no eppreeinilla Charges ill wvlor thzT.ts:n:
Aeselu%h also shoos that the herbicidal activity of Sonar does
no; resn1i in a L2rge reduc:lon in the di=solved oxryter. content
of water, Sonar perm',:. the natural cyds a! decomposinn�
respiration end reaeranon to rernein essamtally in balance.
A!inough attached colonies of algae hova been observed on
dying vegetation, diesc a!goe disappea- when r, eeds r,top to
the Liouom.
There is no eiadenee of consistent, sr.bsantisl'mcnases in
nutrient concertradons annbutablz to release fmnl tared
vegennion. Ih!s nray account for the la-,k o:' m�iwca algal
b!oonts foCoivigg treatment.
Metabolism & dissipation io water
The rraximUrri solu'o!lity of 11' tldonc in ai,[e, ^P,,Tok
12 epm, or bcut 100 times s concentration in ,cater lmrna-
dlw:zlc after an pppl=non n i; 5aonar (whin applied worcl-
ing to IG lobe:;. That means Ccrd:me comple:e!y diss?Ices,
and is midlly- available for p's-.: uptake
Under geld conditions, Sonar gradua!ly disappers iron.. treat-
ed l% TP.e half?jie o:'t"m:^dene nr water aver lass 20 days,
but-angta from .ve in 60 vacs, depending on em{ronmantal
factors. in lakes, reservoirs, car.a:s and rivers, whore often on!)
a portion of :he waxr body wetkas ifeat mem dlludon
reduces Sonar nmcaneatto^s icc'rzr.
Sonar disap, ear front aquatic zm-uon:vents due to one oe srv-
eril of toe following factors'.
Phomrtegradarlor• Uftracio:et h=ht, a component of sunllgly,
doeomposes hundona. V^ ,, r tha pnmz � proczss eontdbat-
:nte:o dissipatin of nutidone:'n'1n eater. Sunlight intensity
and dcraunn, pies water clrmr and depth, all'ect the raze of
plaomdegr:tdatlon In photodgnda:ion scdits conducted coo-
wars in natural sunl::nt. aur.Aor.e photodegmd!d to 30 Per-
c1n: of is mn;T; toncenrracor. whh(n fin:r weefcs after r-o lica-
nor to wntar
Plat uptake. Uptaka occurs znPidly. and continue, unl:l the
flandone concentration it, cla-ts cvecads that in water by se�-
en fold
Hydrooil adsorption. Fba'!dcne resin:ucs he hydxmot! nornnl.
ly reach a inlLo turn heal on¢ :o fox ivecke after trzatment,
and ueual!y decline to level after 16 to 52
weeks— depending on eniirunmenul factors. Fl aridone dissi-
pates:tom the hy'dl'osoll gradually by - absorption by plant Toms
and desorudon back irm the wn:er, idlere it Ls photode�rac!ed.

AUG-23-1999 MON 05:22 PM DJJl WATER QUALITY
i
FAX N0, (�97339959 P. 11
JUN-2v0-1S3A 1U:59 S'�ERRD COR.PDRATSON 217 590 0'"�9 P.aly
I I
TOxlClty CIansificatlnn
The Enairotnnanlol Protectionngency elasssfres pesacdes
acrording 10 their accte toxicit)I and regAiras that a siymal ,card
indicating the acute touchy caregoly of dx peaticiae be dIs-
p zyed p:onnnently on the product label, Sonar lrekdde
lobe's display the signal ward CAUTION. The CAUTION sig•
nal u'3rd is displ iyed on pradreis classi5ed in One leas: aculely
w,\;C c8!egomii of Ihs rating 5yslem.
Mammalian toxicology
Researcher hive conducted emensh a snldies With la:oora:oty
animaI3 to ddl ,,one tie tmoc.ogy of lundona, Studies have
included acute towitr, subchronic and chronic Ulxic; )t tara-
tology, iep,,cl fon, muragenin and O minogenic evaluators.
Study results in ;cafe a lo,v order of tox(cily to mumrlA fen
species 1011,ming acaa, scbchmuie or chmoie expa.n•es.'n
addition.la.ge, renen;ed doses of Ilu=done did not:esdt In the
development of Wft%Ors, impairment of -CPO duCR '.. do
Ina! deceiopnrent of offsuringor indcc0on of tnutar:ens.
'Cho mammeUan roxiciry prnF,!e deceloned through thewuJ-
ics euppom the Conclusion that Sor.zr prums no unreaeor:
able risk to humans when used •according to One prndacts .*el
direcdors And Pmcaudons.
The FPA has Te 1, tad Sonar with rit rewic[imas on v,e use of
treated water for 3,.,..nndng or fishing. The F24 has approved
an accentaole residue level of 0.13 pptn for nuridone :n
potable water used for ddniing pc7..Uee. F\ ne:e Sonar s
applied to lakes and raszn'oirs selling as 50,117es 0: pot, -e
a,i mr, the label prohibits application within one for<h miia of
PRY funclioningpo,abte wter intake.
Cardnogrnid[y. In lifetime feedin, swilias in, rats and mice
Conducted coat a tw'o-year last period, Sonar showed no
evidenra e(hein; a potential carrinogen, Fluridone is not listed
as a carcinogen or potsntial carCIROgcnby LiRC, Nl:'lN1P,
OSHA or ACG1k 1.
Miltagenicity. A ouniou of nt vivo and in r,:10 tests were CO:l-
ducted :o detenn9:e IF dutidonc caused ait3unon ar darraKe to
genetlt nlaleriplFullowing a singe Prose of 2900 I lend, fla,i-
done did not eeuse d6n!nan[ lethal mucac:its In rat;..\ hurl,
dune dose of 500 rtg/kgdid = cau.0 c'cocm;omal damage
I-, hamster:. In ar%Am,', test for bacterial:nu:auon, nurldone
vitas showT not to:nduce [n ainlons s, six hl;hesr lewd coin:
centration of 1,000 ppm. In add1111-1 Ilur:,:tone was sh"" nut
to Interact n".th genetic material iDNAi when Tested A a can-
ce:urution of 300 ppn In the cult[:~id hepnucvru test fur DNA
damage and repair
\'enrotoxicity, Dow•E1'lne0 scientists 114,YC CC,7,(I; d estensce
toucoinjo1 studies in lahormnry aWniMi ex2ose6 to Iluti-
done. None of tl'.a ebsenaalans ct hqh dose ba-eis indicatrcl
nen'Ous 55'atem egws.
Reproductimt, To examine possi'aie eFec;s or: repror,odon,
nurldoce was nd-,roistered sap y to fats.-nd cxlauits corrdnu-
otr5ly suing the ca_gnagtnesis phase o! emb'jronle de@elnp-
men:. T ;Is pl+aaa is the pedad of development of specific IN -
sues and nt;gana and 4n en aspeEleiiu sW,�it-re t:t'na for the
express:an bf devetupmental detects. Flttadone did not Wut+St!
developinetual def,eCls at the raauTum coats of 200.
mg('.-giday in its or 750 tng/kVday in ntoO e.
aus uuintained fur three s::a es4•vn gene:ar.ous on diets con-
taining 2,000 PPra fWrtdone (121 In g`dac) showedd, no
inlpaisnen, of feta;dy, lieehurn litr_r site, penal of enrbp anic
development, arabryo stuviczl, stir,'VPl of 1,,5prin; ar sex dls-
Lnlnmon of offspring. In addi003, t'..efe icas no e\hdmce of
I'uddona�inducad defects In en:ownlC dmvelnprr.tnt.
Slain and eye inimtio0.. =anar h e been ciasr.Rzd es• .alightly.
Irfitaling t0 Cyl^a. tilen'any Pmjdde, '_"a re%n1n"Andad
application technigce5 and wa etyegttiptnet:;, and h7ndk
pranerly to aiUid ee;wstat er skin . , C7.o

AUG-23-1099 MON 05:23 PM DL- WATER QUALITY
s'F.FRo oORPCrtarloly
FAX NOr (11197339959 P. 12
s1r sao r_'�•a¢a.m'�
MAMMALIAN STUDIES'
Slud}'
Retiup;:
Cmm�mnrs
Cm. SD„
�Or&altistn
n6musl'
a:U.0007,L/ug
\'¢p•Im<te:dchY.
rlq
.h>AN *s/ng
\tly lmt'lvldj',
4
rha,al'.tn LC
L.
"m
' ,a �n 4n vnr
fiurhC
Wl,n;, 11 eon 3J11h ^C .ue4
>9 UJ0 i }
\ F cn o`
hnll 1 t 1 e 1.-, --
SkVnsrs;cnllaa
w gslnea ptc
nauca
0,1 ir2 da)'sl
'atuuse
62r?I'
P'o a.e'r;.tnl•re!n:w! vc,co
MEL)
L9.3 mg �;yda}9
:1b,:ani•L et Ihaec d"',
.yt
]3d '211
Ap 1« a.rrn tlu f C'Is
ob^Lncd s
diit
mv.ellldall
,OIgAh`t rttl I !'dry th,4 l.0
IitrnlA..!I dT:i)
n11f .w
NC elneursic IaNicll\'
'Ita.Pa 9l >1,L^sCIL110 ,1C4iWA!.I
ahscn'ed. �
sspeasien. ..._
�,�"
���rdf„Ve(1f)
� lnaLlie
.�l1 En;n �
.g.eW.Cs
I �'u',ukK CreL'I311'e i0:5(n'fd,
nn
2C07pa
N'o loslcoleo tl11 tl5rm o6sen'e6 ae
0 +rag•1:gdsyq
?ris IV, el.
do,)
;301n m4mi dny
Na coNleeparcal eiYe[u obselad at
s!avel.
Orsl ?yeool•
:ncme.
TO pant
Ku gmee;esic elrtts:ccre
ill6ms",jdnyt
ckcn'ni: no .,'dtl:Pe al
,NC.F13
s<ineyrr:,L: tf.`mts in swu i
rlil
2'JP:on
N a lmre c3;cti e((eas ulsser t' nI
'
;tli:ercl. ne eddenca or<nrcia. me
elrecis In smc'p.
1 ..2. : ! 11 rl h J 1. ! u.
:..'n6v In o1Lt ,,. mr L nlaNc..,x,. .., f%,h0e•a,.:.,h1, 4, :r,. r,: pep- n., l.p.<. „e+, '. r ..r:tla ,.I FP,.:. is
Sra!enM1mu,lNr :haay.:nh r,..01>,xng
J. d.:.::mv.•n u'.i�.r:.....•.u.a, nl:,;..InV ila",n:Y!:✓.n �,gv.C¢.:r.e rllb,N N L!w 4:ilprevl ruau•..nl.f.l:n 5. �� er. estt_. N:ryqup a: P.:.::.rp:.nJ
.x i. o:ab,. m.n. r. n.ar fm:. n•je: :
Birds & other nootarget life
.AVIAN, EARTH WORM AND HONEYBEE STUDIES'
dy
Organism
Results fppni) !
comment,:'a
ocnlLD;
r S rKU Inuft; 1
]c nlottehp• obxnzd w Lrw leeelbay
:1<`tny
hglm hNa5.M)
Ulan in dtt!
No manriny' nbscmcd i'L`.he4V_
i.JJO prat In d!es
I .Cu mni.k tl' obscrred at lresx'F1'41--.
..,n^e.c;vnuxleNmaliard
F
NOEL t, S.dJd 7pn, 10 d1e1
So ubiunmd crrt:^s mjuvelrilei rr
___
�nsrt
_-.
6ex
___
561.h µ(y1wN
Nomortihit obtva¢dat 1liega;:isnt
,e;
cerh„ ami llA•dap)
LC,> IN 6 r�\o
m.:nalVj ohalvud at Lhrz IaceL.
. r..mf uvrc nn.rim;rs wrmho¢nl IlarAano. Ps nano mhmeiam miwm: hrn:c:eue

AUG-23-1999 NON 05:23 PM DTIZ) WATER QUALITY
Jul •1-20-19'34 lt:n9 _EPRO CCIRFLTRFTION
FAX
N0,
1R,197339959
P.
13
Aquat c life
FIundone 1,as bet ntested In acute and longer -term laboratory
studies in fish and other aquatic animals Fish exposed to
wear treated v ffi Sonar absorb low levels of fluridone. Edible
fah tissues contain lower (:undone concentrations than inedi-
ble tissues. Residues of fluridone and its merabDh@ in fish
decrease as the herbicide disappears from treated water
p:undone has a law N-Ocmnol water partition coefficient
(1ug'Xow = 1.87) that indicet25 it will not accumulate in the fit
of Fis!i, reptiles or mammils. the EPA hss granted a 0.5 ppm
Tolerance for atirijone and its metabolue in fish.
FISH, AQUATIC INVERTEBRATE R
ESTUARINE AN➢ MARINE STU➢IE5'
Organism
Exposure
1.C„/EC,,
ppm fluridone
Freshwater Fiah
aluemll
90 hour
12.1
rainbow null
96 hour
4.2
dvnnel cafFsh
96 hour
F?
i.dieadminnow
96 hour
32A
Avail, Invertebrates
Diphnie(dap4id)
48 h0ur
39
C'afnwaNi(alnpbipOdy i
96 hour
? 1
Chuonaulas (hnidga)
a8 hour
L1
,regnsh
l4day
>169
Eamarine NMmne T
pink shrimp
96 hour
4.6
Hut crab
96 hour
34.0
0".51" ouahp•osaarvae
•5 hour
15.9
chezpsheod r!nnmr
96 hour
10,7 .Y
FISH AND AQUATIC lh'VERTEApATB LIFE-CYCLF. 57rUO1E5'
Organism
Expoamm
NOEFFECT
CONCENTRATION
ppm
Pundo�a
.9rhend mfnnaw
30 day
0.43
<nnanet<mEsh
60 day
0.5
0aphnia(daplumm)
21 day
0.2
C'.nmmans (arnphipod)
60 day
0.6
ofiononuis (midge)
30 day
0.6
Pets & livestock
"toxicological msrina Indtcares dLar wt-,nn ussd aecnrdin, to 1F.e
label, Sonar poses no unreasonahk risk to pets and licesmck
due to its law order of-miin nialmn mzi_iq•.
melts
The Inette in fonrulat a-s Of aonar ore not on the FRA' list of
hens of Tos4cologica'. Concerti • (11sr 1) or im: cf "FD;entially
Toxic InertS / Higla Etimity (a¢ TCS:In,°,, • (la 2).
a.9 x fo�>f �mi0
5ven•, wars mnaundrv4h awdere:he x�a:e NarvOm m S:n+���buile

AUG-23-1999 MON 05:24 PM D1J(, WATER QUALITY
FAX NO. 1Q 97339959 P. 01/0-,
Directions for Use:
II is a vi.letlon of Federal Law to use this product Ina manner Ineonsis.
lent with its knout.
Road all directions carefully before applying.
Sh aka wall before using.
STORAGE AND DISPOSAL
Do not conlaminato water, food or feed by storage or disposal.
Storage: StON) in erigi n at contai nor only. Do not store ne at feed or
foodstuffs. to case of leak or spill, use abso, ben m9aftle to con A! 1
liquids and dispose as waste.
postl aide Disposer. Wastes resulting from use Of this product may
be used according to label directions or disposed of at an approved',
waste disposal facility
Container Disposal: Triple rinse (or equivalent). Their offer for recy,
cling or reconditioning, or puncture and dispose of in a sanitary land-
fill, or by incineration, or it allowed by State antl Local authorities, by
burning. If burned, slay out Of smoke.
General Information
Sonar A.S. herbicide is a selective systemic aquatic herbicide for man•
agement Of ac oath Vegetation in h'con water pond s, lakes, reservoirs,
drainage canals and Irrigation Canals. Sonar A.S. is absorbed from
water by plant shoots and from hydrosoil by the roots of aquatic vascu-
lar plants. It is Important to maintain the recommended eonoents lion of
Sonar A.S. in contact with the weeds as long as possible. Rapid water
mnvemant or anv condition which results in ranid dilution of Sonar A.S.
Sonaf A.5. Irihlblts the formation of carotene .ln Ina absence of
carotene, Chlorophyll is rapidly degraded by sunlight. Herbicidal symp-
toms of Sonar A.S. appear in seven to ten days and appear as while
(ohlororc) or pink growing points. Under op lim um COndi lions 3010 90
days are required It store the dashed fowl of aq onto wood man ag a.
ment is achieved with Sonar A.S.. Species susceptibility to Sonar A.S.
may vary depending on time of year stage at growth, and water move-
ment. For bast results, apply Sonar A.S. prior to inhlarion of weed
growth erwhen woods begin active growth.
Sonar A.S. Is not eorraalve to application equipment.
General Use Precautions
Oa
sAftel-Application
Newts Seeded
crop. Seedbeds
or Areas to he
established
Planted Including
Application
Established
Row Crops/
Overseeded Golf
Site
TreeCro s
Turl/Plants
Course Greens
1Pondsand
SARO Canals
7
30
30
Canals
]
14
20
2Lakes and
Reservoirs
]
14
14
Obtain Required Permits: Consult with appropriate state or local
Water aurrodtios balers applying title product. Pormits may be required
by state or local public agencies.
Chishru len: Do not apply Sonar AS. through any type of Irrigation
system.
,Potable Water Intakes: In lakes and reservoirs, do not apply Sonar
A;S, Within one-fourth mile (132D lest) Of any functioning potable water V:
.intake. ,•�(
irrigation: Inigarion with Sonar A.S. treated water may result 1n injury
to the irrigated vegetation. DowEtanco re commands In farming those
who Irrigate from Sonar A.S. Ira aced areas of the fulgatkol Il me frames
presented In the following table. These time frames are sugg esdon8
whim should be followed In reduce the potential for injury to vcgstalion
irrigated with Sonar A.S. bested water:
t For purposes of Sonar A.S, labeling, a pond is doffed as a Lady of
water 10 acres or as, in size. A lake or reservoir i3 9'ealar [Iran 10
acres.
2In lakes and reser,oire where one half or Dr ter of Ilia body of water
Is treated, use the card and slatic canal irrigation restrictions,
Weed Control Information
Vascular Aquatic Plants Controlled by Sonar A.S,
Floating Plants:
Common duckweed (Lemna mount
Emersed Plants:
Spallerdock(Nupharlutaum)
Water-lily(Nymphasa spo)
t'Controlled only with a surface application of Sonar A.S.
Submcrsed•Plants:
Bladdclwod (UMcukiva spa)
Common Coonel (Ceurephyllurn damarsum)
Common Eledea (Eledea canamPr t S)
E.geda, Brazilian El.dea (Fgana denaa)
Fanwod, Cabomba (Cahombs caroan:ans)
Hydrilla (f4ydols vcnlcillata)
Naiad (Na(asspp.)
Pondweed (P010MOgOO11 sop., except 11100is pondwood)
Watts tail (MyrOphytlum spp.)
Shoran.. Gmssas:
Paragrae6 (Sinchlone moiled)
Vascular Aquatic Plants Partially Controlled by
Sonar A.S.:
A1110M.r, ..d (Almmanthara phlloxcmidcs)
American lotus (Nolumbo Iut$A)
Cattail (Typha spe)
Common water meal (Wol(iia columbiana)# i
Creeping Waterpriminse (Ludrvigla peploidas)
Giant cutgrass (ZleranPopsls mlllaoea)
I Ilinois pondweed (PolamogePon illinoensis)
Panorfcather (Mynophyllurn brasilicnsa)
Read Cimar ass(Phllarls arundinacone)
Smallwood (Polygonum spp.)
Spikerush (Elocchans spp.)
Southern warrantless (Hyd,nchloa caraliniensis)
Torpedograss (Parecurn repens)
Wolorpureano (Ludwigla palustris)
Wate)shfald (Rrssenla schscbep)
'''(,tp9nlHl control'onlywith aSGBaco application ofSone`IA.Sjel`-
":Ihe maser ;rl'laheled role., "
)

AUG-23-1099 MON 05:25 PM DA. WATER QUALITY
FAX NO. (197339959 P. 02/1
WARRANTY DISCLAIMER
CowElanco warrants that this produot conforms to the bhemloal
description on the label and Is reasonably fit for the purposes stated on
the label When Used In strict accordance with the directions, subfect to
the inherent risks snl l fill below. DowElenpO makes no other
express or Istiff led warranty of merchantability or fitness for a PH -
ocular purpose or any other express or implied warranty.
INHERENT RISKS OF USE
If is impossible to eliminate all risks associated with use of this product.
Plant injury, lack of podormance, or other unintended censequsnCea
may result because of such factors as use Of the product contrary to the
label Instructions (including conditions noted on the label, such as unfa
vorable temperatures, sail conditions, ate.), abnormal conditions (such
as excessive rainfall, drought, tornadoes, hurricanes), presence Of
other materials, the manner of application, or other factors, all of which
are beyond the control of DowElanco a the seller. All such risks shall
be assumed by the buyer
LIMITATION OF REMEDIES
The exclusive remedy for losses or damages rasulting from this product
(including claims based on Contract, negligence, strict liability, or other
legal theories), shall be limited to, at DowElanco's election, one of the
followin9�
(1) Refund of purchase prise paid by buyer or user IOr product bough I.
or
(2) Replacement of amount of product used.
DowElanco shall not be liable far losses or damages resulting from han-
dling or use at this product unless DowElanco is promptly notified al
such loss of damage in writing In no case shall DowElanco be liable for
consequential or incidental damages or losses.
The terms of the W afranly Disclaimer above and this Limitallon el
Remedies cannot be varied by any written of verbal statement; or
agreements. No employee or sales agent of DOWElanco er the seller is
author! %Qof to vary a exceed the terms of the Warranty Disclaimer or
this Limitation of Remedies in any manner.
-Trademark of DowElanco
CopyrighV:a 1992 Dow8ab00
DowElanco • Indianapolis, IN 45266, U.S.A
LABEL CODE 11336.003 DATE CODE 892
EPA APP ROVAt. 07/21W REPLACES 11336-002
Revisions Inoludo'.
1. Sonar A.S. label reformatted and edited for clarity
2.. fnvifonmonlal Hazards section updated.
3. Use prohibition in areas used for crayfish farming removed.
4. Woods (plants) controlled section revised and plants "not controlled"
by SonaM,.5, added
5. Application rate recommendations for ponds, lakes and reservoirs
rained to provide more accurate control of herbicide cencenpations
In water.
6. Procculions section revised as per EPA request.

BASF Corporation
PROJECT SCOPE
ENGINEERING JOB NO.4427
KF- UPGRADE ENKA WASTEWATER TREATMENT PLANT
AUTHORIZATION NO. E-4922-4427
SITE
This project will provide for the mechanical and instrumentation upgrade of the wastewater treatment plant. This
work and all new structures will be contained within the existing physical boundaries of the present wastewater
treatment plant and the lift stations.
MAJOR EQUIPMENT
The project will purchase and install the following equipment:
1. New instrumentation that will monitor the influent streams and will provide system operational data.
2. Two (2) new subsurface aerators.
3. Three(3) subsurface mixers.
4. Two (2) variable speed drives for the existing constant speed aerator drives.
ELECTRICAL
The existing wastewater treatment plant electrical services will be reused as required.
INSTRUMENTATION
New instrumentation will be added at the lift stations and at each intermediate step of the wastewater treatment
process. The instrumentation will be tied into the existing CSI system. A personal computer will be provided for
operator interface in both the wastewater treatment plant control room and the filter plant.
UTILITIES
1. Electrical power will be provided from existing substations.
2. Air will be provided from the existing wastewater treatment plant compressors.

DEC 09 '93 09t01AM O-)PLANNING ^ P.1/1
l
Appro
' Request
all F � ' zz) L J�a. BASE
Request F 60 � S T E'. i i
matm�xeo.
NM I MMA,NC I T.RJOHNSON
4397 j &492Z44Z.
Enp,,eh ..t Capital Rearrange. Repairs OtMf E%pennon T¢rat Cxpamea Total Pmpe[
Trial 580 10 10 590
"a project Includes environmental &penning at 590 K &&festal bavad nnpmlamrenenwi
Coot Aaeoun[ ossenpnen
The following forms an not Prior ApprovSis ($Iq
applicants or an not 75
- Prior Approvals:
❑eatery ❑gm nvirnnentei This Request!515
�utllluee �geenolnios Total: 590
Project Description MmcR eeyPpplicenanasathael
This project will uttered. ch...fail., w.amramr treatment plant by installing new monitoring equipment and replaefng certain Praefl,
equipment. An engineering study of the treatment plant wee done to determine the ina famentrtlon and equipment to be ineloded in t
avocado pto}aec
Justification tUroWndgAppdst on Ala NdnnYdl
An upgrade of [ha outerater treatment plant will ensure that the guha Plant meet, the requirements of the N,tia,el Pollutant Diller
Elimination State. (NPOES). The ability to stay within the limit. el the permit beaem.a marlia.l duri., at twma ambient oo¢didam
and who¢ ....solve organic loads are received from the mmufssluring treat. Two A.w process (Conduativa Fibers and Anti,ut) hive
introduced additional lead. t. the latest. The .pared. of therssmwater treatment Plant I. required ,, handle oPlats en homing
,,name and to provide <flfef.nt operation. The content of this project was developed from a study made by an Outside engineering fir
Ih. aarperata Saola y Group support¢ the Pruitt' cad PartialPatad in It' d""'Pment.
� - . fii�•�
��
�iaa . I
fw
� /�
�

......._.___............ .
n
PROJECT ACCOUNTING SYSTEM
SOURCE DOCUMENT
AUTHORIZATION NUMBER I E- L+q zz, _ +-Z
PROJECT DESCRIPTION {(j-- C4P(C+aO' Fk KN WASTEWAIf PLAN'
PROJECT ENGINEER Grp [34 �
AUTHORIZED AMOUNT AUTHORIZED DATE �/ / 7 i]3
DEPRECIATION COST CENTER J PROJECT TYPE
ESTIMATED COMPLETION DATE I 1%131
START QTR. & YEAR 5 START-UP DATE
PROJECTED SPENDING BY QUARTERS:
OTR 1 $ %/,Q . 00 K QTR 7 $ K
QTR 2 $ ZCQ. pD K QTR 8 $ K
QTR 3 $ /00 .0O K QTR 9 $ K
QTR 4. $ IC(0 00 K QTR 10 $ K
QTR 5 $ K QTR 11 $ K
QTR 6 $ K QTR 12 $ K
COST ESTIMATE
•�DESCRIPTION
5 • oWme
i
KUM
Emil
i•
cw�l
+ •
NS0�
,•
+lir
� mar ► +
�� •..

BASF Corporationr)
BASF
CAPITAL PROJECT COMPLETION NOTICE
AUTHORIZATION NO.E 47a2 - ¢ ¢g7 AUTHORIZED AMOUNTO.2 Qop
PROJECT TITLE (fpSegaE nACq /,r/as�c „rgrF %,ors —Air PtgxJr
LOCATION
COST CENTER ¢38,:T COST CENTER LEADER J,<a. , , , ,oErj
All work authorized on this project has been completed and a final
operating type safety review has been performed. The project, as
installed, meets or exceeds all Federal, State and BASF Corporation
safety and loss prevention regulationsand standards, except as
stated below. Effective this date it is released to the owner for
operation and maintenance.
Exceptions:
�: 1,�r
/z
PROJIE!%CT EN�G(IN�EER
DATE
C _ �.C.l�
�Z /!c-• il'
ENGINEERING SUPERINTENDENT
DATE
�����
MAINTENANCE/CONSTRUCTION
DATE
DEPARTMENT REPRESENTATIVE
DATE
p
/`i�"1 � 2,C
/ Z z / 9
SAFETY REPRESENTATIVE
DATE
ENV NTAL/INDUS. HYGIENE
DATE
Enka. North Carahm 26726 (7N) 667-7110 / - _�
_-::/-:.-

riecluest 7 BASFC')rporatlon
BAS
ECR ❑ SAFETY ❑ EIT
11_OI.V.IIJII
t� L¢�
D
Department r—a 4 art Dept.. Acct.
Date Issued % -. / z* - 9S
Date Required
r7�" '''`"
�//o - wk
Auth. No.
Account No.
Eng. Job No.
FNA—lll
9a 5 - Sa 8 3
5 O i5 3
Title:
sirlFHTI)la
ni Istl
I IAlla Isal'I PI I.-I'lAl
Description of Project Q [
2
LL Z'NST wM-a ,'a r/
Economic Life
Tax Depreciation Life
Description of Disposal
p
erc
/ 6
SS 1 STi
Disposal Asset No.
Original
Cast $
NBV S
Estimated Loss on Disposal (Net of Estimated Proceeds of S
I is .................................................$
Estimated Cost of Dismantling and Disposing of Assets..........................................................................................$
ACTION TAKEN BY ENGINEERING
Assignedao - Priority.
/
Safety Review Complete _Yes —No
Project Engineer
Date Completed
e—' -/G - q
AUTHORIZATION COST ESTIMATE
CAPITAL EXPENSE
EQUIPMENT $ �52a $
MATERIAL $ 306 O $
LABOR $ .i 6 o a $
ENGINEERING $ 10 a a $
CONTINGENCY $ ;L a a a $
SUB —TOTAL S _ $
AUTH. TOTAL $ So a
z
F O
U—
Q , Q
LL O _
� 1_
a" Z
SignatDate ure
Requested By %
Superintendent
Or Area Coordinator
Manager
Z
O
J H J
t j
G — O
O o_
z F=- Q
D
Q
Controller
Manager
Plant Engr.
Gen. at
���/�,
re
/
DISPOSAL AMT. S

PROJECT ACCOUNTRI SYSTEM
SOURCE DOCUMENT
AUTHORIZATION NUMBER I 4,70E- .J o B9
PROJECT DESCRIPTION k 4 gi,Ad � ' 4' y' 5
PROJECT ENGINEER
AUTHORIZED AMOUNT AUTHORIZED DATE u _ 23=9
DEPRECIATION COST CENTER p /f 3 PROJECT TYPE
ESTIMATED COMPLETION DATE - 9
START QTR. & YEAR F-JT7 START-UP DATE
PROJECTED SPENDING BY QUARTERS:
OTR.I $ // K QTR 7 $ K
QTR 2 S S S K QTR 8 $ K
QTR 3 $ K QTR 9 $ K
QTR 4 S K QTR 10 $ K
QTR 5 $ K QTR 11 $ K
QTR 6 S K QTR 12 S K
COST ESTIMATE
CODE
DESCRIPTION
AMOUN-
o 'Coo
FLc t.. SN
7fao
90 0
5 Gc� ;,N Lf� ar
S'000
0 7f

PROJECT OBJECTIVES MEMO
sIlk
Date Written: 7/3/96
To:
From:
M. A. Mc CALL
C. E. Hall
APPROVED
Location/Extension: ENKA / 7867
Subject: REPLACE SP2 AND SP3 EFFLUENT PUMPS
COMPLETED
Copies:
Action Requested When Completed PLEASE APPROVE THIS POM AND FORWARD TO
ELAINE SCARBOROUGH IN PLANNING & CONTROLLING. CHARLOTTE.
This is a request for Scope Development Funding ❑ Project Appropriation
Project Statement REPLACE SP2 AND SP3 EFFLUENT PUMPS BY OCTOBER 1996 AT A
COST NOT TO EXCEED $25,000.
Project Objectives PROVIDE RELAIBLE EFFLUENT SUMP PUMPS IN THE EFFLUENT
HANDLING SYSTEM FROM THE EVAPORATOR BUILDING AND LACTAM FARM BUILDING.
Technical Description of Proiect INSTALL FOUR (4) DEMING TYPE A SIMPLEX VERTICAL
SUMP PUMP ASSEMBLIES IN SP2 AND SP3 SUMP PITS REPLACING EXISTING PUMPS.
Justification EXISTING PUMPS ARE WORN OUT AND REPLACEMENT IS MORE
ECONOMICAL THAN TRYING TO REPAIR EXISTING PUMPS.
Funding Requested ($K)
Approval
Approver Name: Tony McCall
Prior Approvals: $ 0
This Request: $25,000
Total Project: $25,000
Property Accounting Information
Date: _July 9, 1996
Appropriation Number
06
Project Mana er
C. E. HALL
Bus./Mfg. Representative
. McCALL
Location
Enka
Site Number
Local Project Number
6048
Engineering Res . Code
!34419
Environmental Percentage
0%
Cost Center
Estimate Accurac %
10%
Ready for Start -Up
ember 30,
Expenditure Breakdown
Z:\WINWORD\TEMPL TE\POM.DOC
REV.V96

0
Wo�
CL
CD
}\
\\\\\
^
W
71
0
a Z r- Li 7
:7
il-
\\\�\\\��
0
MWINOM
\
9
D
\
Z� -
77
71
z
z 7,rw
a C
L:
7 0 Lb
ci D r�
'5
n
z m
71
\!\
\
m 0
,>!_,,,
0>2m�m=
, 0 0 E: M 1 55
MM
E
MMOM>>,
omm
cl:
1
/
Z>M�Zzo
1�
OOM5>c=
Z>' M�mw
omm�2mm
.
MFW,�o
Fn
>
zo ,m M

Ergj_ect Request BASF C!^�Ooration
❑ ECR ❑ SAFETY ❑ EIT
D
Department jElel-5 Depr. Acct.
Date Issued �'- ,(f, �% S
Date Required
Auth. No. E- 4-90$ - ,$662-
Account No.
Eng. Job No. _50 8 2.
Title: Id I11,44c1d I'/'I r.-li Ikl it dl :I71XI I9I¢I✓1 il�j,1 1417-I IBIOIDI 1
Description of Project
Economic Life Tax Depreciation Life
Description of Disposal
Disposal Asset No. a I/ ? ° / 7 ° Original Cost S Q�. 9F. / 7 NBV $ X6 . IvO
Estimated Loss on Disposal (Net of Estimated Proceeds of $ I is .................................................$ '1 - G
Estimated Cost of Dismantling and Disposing of Assets .............................................. ............................................ s
ACTION TAKEN BY ENGINEERING
Assigned to Priority I Safety Review Complete Ves _ No
Project Engineer
Date Completed. 0 -
AUTHORIZATION COST ESTIMATE
CAPITAL EXPENSE
EQUIPMENT S .9660 $
MATERIAL $ l 0 o 0 $
LABOR S 4000 $
ENGINEERING S 1 06 O $
CONTINGENCY S l° o O $
SUB —TOTAL S $
AUTH. TOTAL S 0 0 0
Z
1— O
U —
OLL 0 Q
R ~
a. Z
Signature Date
Requested By i-//-{-9_
Superintendent
Or Area Coordinator
Manager
O
< Q>
N O
Q.
Q.
z I=— Q
O
Q
Controller
Manager i o/
Plant Eng'. IU G /
Gen. Manager C
DISPOSAL AMT. S -2 14 .oe

MpY 21 '97 14:42
24S 'rbl/l"i
Memo
Post-r Fax Note 7bfi
0"°,�%/-97
popes► %
To _ACAgr y. H.ttt
Fm A_,2, ydre
cploea.�jSF '
o°.rlav�+[�luerw.+
Flo.
Fk A-1-yea
•.• 7 ,667-73aP
�.J3/,z
FUY IOZ sTTX
J
To: Mr. Dewayne Mills - BASF Corporation - Enka, North Carolina
From: Tom Snyder -National Bureau
Date: May 21, 1997
Re: Personal Property Tax Valuation Service
Dear Dewayne,
First, thanks for the data on the proceeds from the sale of abandoned equipment. I would hope that the
assessor finds that $61,000 proceeds from the sale of equipment having a first cost of $4 mifllon
compelling. Let's hope this issue is put to bed.
As we discussed on the phone lest week, they continue to raise other issues, however. 1'd appreciate
your response to the following Inquiries or requests at the soonest convenient time.
1. Re: Exempt Pollution Control Equipment
The assessor maintains - and correctly so - that they cannot exempt properly not
covered by a TAX CERTIFICATION. She has four certifications on file - copies of these follow. - which
cover assets through 1995.
A) Regardless of date or what equipment Is involved, do you have any other
CERT7FfCA77ONS in your files anywhere on site? If so. please provide me copies.
B) Machinery capitalized in INS with a cost of $574,902 was for pollution control. - See
list which follows. Was a tax exemption application filed for any or all of these hems? If se, please
provide me a copy of the application.
C) Concerning this $574,902 new pollution control equipment- Can a case be made
that this wasn't a new installation, that it wasni additional facilities, but rather was unfming, rebuilding,
repairing, revising, replacing, improving what was already there and covered by one of the existing
CERTIFICATIONS? .
2. 1 need a list of leased or rented equipment that was on site at January 1, 1997. The list should slow a
brief description of the item. the name and address of the owner. and the amount of either the monthly or
annual rental or lease payment.
3. 1 need another listing - the same thing as in question two - except for January 1, 19%.
4. 1 need a copy of the capital acquisitions request fAPPropria0on 33609M which supports 1995 asset
number 00045320000 *Fire Riser Monitor System for Enka She with a capitalized Cost of 5259,1149.
There is an Issue as to whether this is a real property or a personal property asset What I'm looking for
is the most complete description of what was acquired andfor constructed forthis $259.549.
Thanks, Dewayna. Sony to have to keep coming back for more data. I hope this is the end of the
requests but keep In mind that the questions come from Shidie Ford - so this Is a prime example of
-Don't Id0 the messengerP
Please call if you have any questions conceming these requests. baenp7d3•sarn

TO:
FAX #:
FROM:
N. C. DEPARTMENT OF PIVIRONMENT AND
NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
59 WOODFIN PLACE
ASHEVILLE, NORTH CAROLINA 28801
PHONE: [phone] FAX: [phone]
60
SAW- Fld-
DATE: A—
# OF PAGES INCLUDING THIS COVER:
MESSAGE: If questions, please call 828/251-6208.

NORrO CAROLINA DEPARTMEN OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
WATER QUALITY SECTIONAsHEVILLE REGIONAL OFFICE
June 3, 1999
Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Subject: Amended NPDES Compliance
Inspection Report
Performance Audit Inspection
BASF Corporation
NPDES Permit Number NC0000299
Buncombe County, North Carolina
Dear Mr. Dellinger:
The NPDES compliance inspection report form included as
part of the February 18, 1999 Performance Audit Inspection
(PAI) report sent to you on March 15, 1999, did not include
effluent zinc data. Also, even though the Vday calculations
for total suspended solids (TSS) are correct, review shows
that the correct effluent TSS concentration was not entered
on the form. The attached compliance inspection report has
been amended to include zinc data and the correct TSS
concentration. The results and conclusions for this
inspection are unchanged.
Please insert this amended report form in the PAI report
prepared for BASF. Should you have for questions. or wish to
discuss this report in more detail, do not hesitate to
contact me at [phone]
//Y/o truly, �,Kg//, -
v a L. Han r 1
Environmental Chemist
Enclosure
cc: Melinda Greene, EPA
Forrest R. Westall
INTERCHANGE BUFLOINa, SB WOOOFIN ILAGE, ASHEVILLE, NC 28801-2414
828-231-8208 FAX [phone]
AN 20UAL OPPORTUNITY I AVTIRmATIVE ACTION EHPLGYER - 80% RECYCLEo110% POST G.N-11 PAPER

United States Envi (4gental Protection Agency
Washh\ D.C. 20460
Form proved
,
EPA
OMB NO03
Approval Expires 7-3"5
NPDES Compliance Inspection Report
Section A: National Data System Coding
Transaction Cade - NPDES yr/mdday Inspection Type InspectoFac Type,
u
1 IN I 2 u I"Ir 3 NC0000299 11 12 99/02/18 17 18 L'J 19 i 2012 LI
Remarks
Reserved Facility Evaluation Rating BI CA
6769 70 71 72u7I ReseJrvIed
' I74 75L
u
L I
I�80
Suction B: Facility Date
Name and Location of Facility InsFacted-
Entry TimeS
Permit EBettive Date
BASF CORPORATION
0830 HR
90/10/01
US HWY 19/23 & NC 112
ENKA, INC, BUNCOMBE COUNTY
Exit Time/Date
Permit Expiration Date
1530 HR$
95/09/30
Name(s) of On -Site Repmsentative(s)/Tide(s)
RAY C. ACKERMAN, ORC
Phone No(s)
MANAGER, ENVIRONMENTAL/SAFETY/QUALITY
(Bone Nuts-7277
Name, Address of Responsible Official
Title
JACK A. DELLINGER
GENERAL MANAGER
BASF CORPORATION
ENKA, N.C. 28728
Phone No.
Contacted
[phone]
NO
Section C: Areas Evaluated During Inspection CODES .y S
- Satisfactory M -Marginal U-Unsatisfactory N -Not evaluateNNot applicable
$
Permit
Records42epom
Facility Site Review
$
Flow Measurem:LLa
Laboratory
Effluent/Receivi, Waters
N
Pretreatment
Compliance Schedules
Self -Monitoring Program
$
Operations b Maintenance
Sludge Disposal
Other:
$
$
N
$
$
$
5
Section D: Summary of Fir, ings/Cumments ((Attach additional sheets if nernssary)
EFFLUENT DATA ( (COMPOSITE) PERMIT .!,b1ITS (MO AVE/ DAILY MAX)
FLOW - 0.632 MOD 1.25 MGD
BOD, 5-DAY - 137 8/D.4Y (26 MG/q 136 #/DAY / 291 #/DAY
TS5 - 527 #/DAY H00MG/L) 209 #/DAY / 565 #/DAY
FECAL COLIFORM -<10 /100ML (GRAB) 20U100MU 400/100ML
D.O. - 8.9 MCA G 11-C NOT LIMITED
pH - 7.90 6.0 / 9.0.(RANGE)
ZINC -- -0.34 k/DAY(64 UG/U 3.65 #/DAY/ 643.5 UG/L -
THE WWTP WAS IN FULL OPERATION. WITH ALL UNITS APPEARING IN GOOD WORKING ORDER.. ONE OF THE TWO CLARIFIERS (SOUTH CLARIFIER)
WAS OUT OF SERVICE FOR ROUTINE CLEANING AND WEIR LEVELING, NO PROBLEMS WERE NOTED. SLUDGE WAS BEING HANDLED VIA THE FRAME
FILTER PRESS. WASTING IS BASED ON THE F/M RATIO AND THE VOLATILE SOLIDS (AERATION) WHICH IS MAINTAINED IN THE RANGE OF 1100 - 1200
MG/L. THE FACILITY WAS PRODUCING AN EFFLUENT WHICH WAS EXTREMELY CLOUDY WITH HIGH TSS THOUGHT DUE TO FINISHING OILS BEING
INTRODUCED BY THE MANUFACTURING PROCESS). DISINFECTION IS BEING PERFORMED BY USE OF A BROMO-CHLORO-DIMETHYDANTOIN TABLET
SYSTEM WHICH WAS PLACED IN USE THIS PAST YEAR. THE DISCHARGE WAS IN COMPLIANCE WITH DAILY MAXIMUM PERMIT LIMITS.
Names) and S gnaturen) of Ins c1
Agency/OffceRelephone
Oate
MAX I. HANER
i
DWQ/ARO 828-251-6208
9�
Signature viewe
Agency/Offire
Date
DWQ/ARO 828-251-6208
- Regulatory Office Use Only
Action Taken
Date
Compliance Status
D Noncompliance
Compliance

DMR REVIEW RECORD
Facility:_ ZJI�J W�7%• Permit/Pipe No.: NCCM02!1 Month/Year:
Monthly Average
Violations
Parameter
Permit Limit
DMR Value
r Over Limit
T
Weekly/Daily Violations
Date Parameter Permit Limit/Type DMR Value %Overr Limit
BCnZ� #, ! Y5 Pn
Monitoring
Frequency Violations
Date
Parameter
Permit Frequency
Values Reported
# of
Violations
Other Violations
Completed by: Date:

EFFLUENT
��@4Rf ApR
. DES PERMIT NO: NC 0000299
DISCHARGE NO: 001
99
MONTH: MARCH YEAR: 8'99Tpp
1999
FACILITY NAME: BASF Fibers Enka Plant
CLASS: 3
COUNTY: Buncombe
I
OPERATOR IN RESPONSIBLE CHARGE IORCI:
RAYMOND L.
ACKERMAN GRADE: IV
PHONE I8281 BBT-7277
CERTIFIED LABORATORY: BASF Fibam
PERSON COLLECTING
SAMPLES: ROSS PEEBLES
CHECK BOX IF ORC
HAS CHANGED
If ONI6INALea6
OIy Dl:6nNMNnQMPI
OEXINR � I 111
ON
frYaC69Rn9M
III;
19K
t� l l l l (t'
I II I I I
SIGNATURE OF OPERATOR IN RESPONSIBLE CHARGE: DATE
BY THIS SIGNATURE. I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
�.0. e4r 2963
II.
(I41 IIII
D
OPEN
OPER
ORC
5OD50 00010
DOM
50060
00310
00010
00530
31616
00600
ODS05
01092
00720
32730
TGP3B
A
ARRIVAL
TIME
ON
SEE TEMP
Im
RESIDUAL
B005
AMMONIA
TOT. SUS
FECAL
TOTAL
TOTAL
TOTAL
TOTAL
PHENOL
BIO-
T
TIME
ON
SITE
FLOW DaB'a
Cl
9200
NITROGEN
RE610UE
COLIFORM
NRROG.
PHO6.
ZINC
CYANIDE
ASSAY
E
2400CLK
SITE
Y/N
MGo C
unit
man
10/tley
Ibl
IEIEeY
/100 m1
mD/1
m9ll
INURY
lb/day
16/tley
P/F
vAI '
"1
III IIIII
F
1
24Hr
0.46
2
III t055
Lim II
AIL,,,.
U711 TW7;;739"1'
71
3
1140
24Hr
0.48 9
8.0
55
88
4
1'4�461
lu$4I{
II
Illl b
IlLi III 9
9.7
I'0i10
79.
q.4
10�.$
.•:»
'',�
.'.':
U
5
24Hr
0.49
LAl
T
24Hr
0.49
$?
S '
24Hr.
(IIIIIII
x: #.4q ra°etA.,
'»�
M8.2
�'
q2(�k
3
III IIIIIII
9
1 1130
1 24Hr
0.42 T
66
1 147
63
7,
lj2a
AL
IV
q.42 '..,'Fl ±
a €�
..'1
a°a$I
�
.'E+`�
.'
-IL
I I I ICI
11
1030
24Hr
0.45 8
8.1
0.10
22
233
13
24Hr
0.49
' III
III; 1
15
24Hr-1
0.50
1$
11P4B,
24}r
0 j 9
7.9
1061
:.
114
iT
1100
24Hr
0.48 10
7.9
96
1.2
384
10`. 5
§4 IIIII
ti (IIIII
I11110,6 V'Id
S1
af'=a0
6
it
"• 'B.
19
24Hr
0.47
1124 ;III
II''ll''I
ql II
-,. 'a
UL
LLL.rxi=
21
2441i
0.59
rr
23
1040
24Hr
0.46 11
7.9
65
96
510
24
+» 11qO
24Hr
�."??
0,4$' 72
]$
'"16
8. s'
"2'.?'
2$LLL
26
1030
24Hr
0.43 13
ED
0.10
53
230
§e
Il h
III'$4r
(III III d,4 IIIIIII III
II
s
. caPs
27
241-Ir
0.47
2$
2411r
29
24Hr
0.47
'30
1050;
0.46
'{
i�
1 44»I
707
t:.,20
III III
;�
;III
31
n10
2aHr
0.46 12
7.9
90
4.6
346
L'IIIIIIII �
IIIII
I
IIIII
I A IH
II
III III ;I
.I
III I
AyBnl,
0.47 10
\\\\\\\\\\\\
0.10
72
2.2
240
22
-
--.
0.20
--
-
....
77
Max. "..
4"v $ 13
$'2
J 1110
IIi
A:6
-'':'$2;,.ti
IUk,I
III 4P IIIII
(III '.0
Iran+lii
ul IJr-' ,I
Min.
0.37 2
7.8
0.10
39
0.4
Ti
1
....
....
0.20
...- I.
-
goro fg3f4MbiGl :':.. i'
1N5 \7Yttid\x G
G
. G
IIIII
G
Iq
II II
III
..',i
911III C
q
h1 III I II
' . ;
Monthly Limit
1.25
6.9
136
209
- 200
3.66
Fesa

Facility Stetus:IPlease check one of the following)
All monitoring date and sampling frequencies meet permit requirements.
Compliant
All monitoring date and sampling frequencies do NOT meat permit requirements X�
Noncompliant
Comment.: On 3123/99 the fecal colform was high due to maintenance work on aeration basin; the monthly average. was well In
°I CBRMy, under penalty of law, that this document and all attachments were prepared under my direction or supervision In
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.
Based an my Inquiry of the pemon or persona who manage the system, or those parsons directly respOmible for gathering the
information, the information submitted Is, to the best of my knowledge and belief, two, accurate, and complete. I am aware
that there ere significant Genelties for submitting false Information, Including the possibility Of fines and Imprisonment
for knowing violations. -
Name of Permittee: Raymond L. Ackerman
Signature of Permittee: . L <iLs.�A.LNtiE�y'rE-�O —1
Date:
BASF Corporation Send Hill Rd. - Enka, NC 1(828) 667-7277 11/30/00
Permilee Address Phone Number Permit Exp. Date
The monthly average for more coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
fircilitys permit for reporting data.
ORC must visit facility and document visitation Of facility as required per 1 BA NCAC 9A .0202(p)(b)(8).
• • If signed by other then the i mm ttim, delegation of signatory authority must be on his with the state per 15A NCAC 2B
.OBOEMMID).
66 03 adV
nr 7y trl >> All c

1DESNO. WC6600v4?` DISCHARGE NO MONTH /Y/aaaH YEAR /999
FACILITYNAME- 6 AS F F, kp s COUNTY � N Nc v,n
STREAM dP0LXy C• LF-EP- STREAM NUN7/,Uy [�+ Q,Fcd
LOCATION SAND NI Rdo✓E LOCATION SAND
Upstream
Downstream
MINE����
EMMMINER11111111����
®111111NEE11111
MINE
-s-®®
®
m
sen�moMINE
ooMINE
�������

Fa...fty Status: (Please ebeck one of the following] {
All monitoring data and sampling frequencies meet permit requirements
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
"1 certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the pus ' ility of frees and imprisonment for knowing violations."
CP t or type)
y
e)
zre-s3
��or mmuttee— Date
PeMittee Address Phone Number
I , I t o f — i Permit Exp. Date
00010
Temperature
00556
Oil & Grease 00951
Total Fluoride
01067
Nickel - 50060 Total
00076
Turbidity
00600
Total Nitrogen 01002
Total Arsenic
01077
Silver Residual
00080
Color (Pt -Co)
00610
Ammonia Nitrogen
01092
Zinc Chlorine
00082
Color (ADMI)
00625
Total Kjeldhal 01027
Cadmium
01105
Aluminum -
-
Nitrogen
00095 Conductivity
00630
Nitrates/Nitrites
01032
Hexavalem Chromium
01147 Total Selenium
71880 Formaldehyde
00300 Dissolved Oxygen
01034
Chromium
31616 Fecal Colifono
71900 Mercury
00310 BODs
00665
Total Phosphorous
32730 Total Phenolics
81551 Xylene
00340 COD
00720
Cyanide
01037
Total Cobalt
34235 Benzene
00400 pH
00745
Total Sulfide
01042
Copper
34481 Toluene
00530 Total Suspended
00927
Total Magnesium
38260 MBAS
Residue
00929
Total Sodium
01045
Iron
39516 PCBs
00545 Settleable Matter
00940.
Total Chloride
01051
Lead
50050 Flow
Parameter Code assistance
may obtained by calling the Water Quality Compliance Gmup at [phone], extension 581 or 534.
The monthly average for fecal coHO= is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reponing data. ff��
' ORC must visit facility and document visitation of fac�iGty 8V'r4L per 15A NCAC 8A .0202 (b) (5) (B).
`• If signed by other than the permittee, delegatibti7�iisiiWallbi�luh?oA'f#;lbust be on file with the state per 15A NCAC 2B .0506 (b)
(2) (D).

BASF Corporation '�-) BASF
June 14, 1999
Central Files
NC Department of EHNR
Division of Environmental Management
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Dear Sir:
REFERENCE: NPDES Permit No. NC0000299
Quarterly Monitoring Report May 1999
Attached are the results of the 2nd Quarter Priority Pollutant Analyses for the BASF, Enka
site.
Sincerely,
A,- e
Ray(Ackerman
Environmental Manager
Attachment
K5
Sand Hill Road, P.O. Box 669, Enka, North Carolina 28728-0669 [phone]

RECOVF.rj
JUN 1 6 Inn
CENTRAL FILES

n �l
QUARTERLY EFFLUENT MONITORING REPORT
June 14, 1999 FACILITY NAME: BASF Fibers Enka Plant
NPDES PERMIT NO: NC 00002DO

RECEWED
Puri 9 6 iggg
CENTRAAL, FILES

Note:
All samples are grab samples taken on May 18th, by Glenn Howell; the flow for that day was 0.464MGD.
I certify that this report is accurate and complete to the beat of my knowledge.
Raym&nd L. Ackerman
Operator in Responsible Charge

JUN 1 b lggg
CENTRAL FILES

n
Pace Analytical Services, Inc.
54 Ravenscrolt Drive
Darc AnAlVfICAl Asheville, NO 28801
BASF Corporation
Send Nill Road
Enka, INC 28728
Attn: Mr. Rey Ackerman
Phone: [phone]
Solid results are reported on a Met Meight basis
Tel: [phone]
Fax: [phone]
DATE: 06/04/99
PAGE: 1
Pace Project Amber; 935705
Client Project ID: Quarterly Pollutant Analysis
Pace Semple No:
93260214
Date Collected: 05/18/99
Matrix: Water
Client Senate ID:
001 WTFALL
Date Received: 05/18/99
Parameters
.................................
Results Units
...................
PRL Analyzed Analyst CAB#
.......... ........ ...............
Footnotes
..........
Natal.
ICP Metals, trace -level
Chromiva
Copper
Lead
Nickel
Date Digested
Net Chemistry
Cyanide, Total, Water
Cyanide
Total Kjeldahl Nitrogen
Nitrogen, Kjeldahl, Total
Nitrogen, Nitrate plus Nitrite
Nitrogen, NO2 plus NO3
Phosphorus, Total
Phosphorus
Nitrogen, Total
Nitrogen
Method: EPA 200.7
ND ca l 0.005
ND ig/l 0.005
ND mg/l 0.01
ND ire/1 0.005
Method: EPA 335.4
ND me/l 0.002
Method: EPA 351.2
3.2 all 0.1
Method: EPA 353.3
9.4 mg/l 5
Method: EPA 365.2
3.6 mg/t 0.1
Method: Standard Methods
13 aIg/l 1
Prep Method: EPA 301D
05/21/99 KEK 7440-47-3
05/21/99 KEK 7440-50-8
05/21/99 KEK 7439-92-1
05/21/99 KEK 7440-02-0
05/19/99
Prep Method: EPA 335.4
05/27/99 MNB 57-12-5
Prep Method: EPA 351.2
05/27/99 We
Prep Method: EPA 353.3
05/28/99 TRW
Prep Method: EPA 365.2
05/21/99 MPS 7723-14-0
Prep Method:
06/01/99 TRW 7727-37-9
1
Laboratory Certification IDS I aboro ory Certficaton IDS
NO Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980
NO Drinking Water 37712 This report shall not be reproduced, except in full, SC Environmental 99030
without the written consent of Pace Analytical Services, Inc.

RED GENET)
JUN 1 6 ig99
errs � FILES

�l
Pace Analytical Services, Inc.
54 Ravenscr0lt Drive
Pace Analytical Asheville, NC 28801
Pace
Ter. 828-254-7176
Fax [phone]
DATE: 06/04/99
PAGE: 2
Pace Project Number: 035705
Client Project ID: Quarterly Pollutant Analysis
PARAMETER FOOTNOTES
NO Not Detected
INC Not Calculable
PRL Pace Reporting Limit
L11 All QC requirements were not met. Acceptable method performance based upon ream thing batch QC.
Laboratory G hlficafon IDa I ab t ry Certification IDS
NC Wastewater 40 REPORT OF LABORATORY ANALYSIS TN Drinking Water 02980
NC Drinking Water 337712 This report shall not be reproduced, except in full, SC Environmental 99030
without the written consent of Pace Analytical Services, Inc.

RECENED
Judd 16 1999
CENTRAL FILES

Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
Pace Analytocal Minneapolis, MN 55414
Tel: [phone]
DATE: 06/00BIjI9612-617-6444
PAGE: 1
BASF CORPORATION Pace Project Nuiber: 1014585
Send Hill Road Client Project ID: 5705
Enka, NC 28728
Attn: Mr. Rey Ackerman
Solid results are reported on a Met xeight basis
Pace Bevis No: 101276897 Date Collected: 05/18/99 Matrix: Meter
Client Seople to: 001 OIITFALL Date Received: 05/19/99
Parameters Results Units PRL Analyzed Analyst CAB# Footnotes
-
--------------- ----------------- ------ ------------------------------- -------------------------
GG/MS Volatiles
8260 Low Level H2O
Method: EPA 8260
Prep Method: EPA 8260
Methyt Chloride
ND
ug/t
1 05/26/99
74-87-3
Vinyl Chloride
ND
us/1
1 05/26/99
75-01-4
Chloroethane
ND
ug/1
1 05/26/99
75-00-3
Methylene Chloride
ND
Wt.
1 05/26/99
75-09-2
1,1-Dichloroethytene
ND
ug/t
1 05/26/99
75-35-4
1,2-trans-DichLor0ethylene
ND
ug/t
1 05/26/99
156-60-5
1,1-Dichloroethane
ND
ug/t
1 05/26/99
75-34-3
Chloroform
ND
ug/t
1 05/26/99
67-66-3
1,1,1-Trichloroethane
ND
ug/l
1 05/26/99
71-55-6
carbon Tetrechlori de
ND
ug/l
1 05/26/99
56-23-5
Benzene
No
ug/l
1 05/26/99
71-43-2
1,2-Dichloroethene
ND
ug/l
1 05/26/99
107-06-2
Trichloroethylene
ND
ug/l
1 05/26/99
79-01-6
1,2-Djchloropropane
ND
ug/l
1 05/26/99
78-87-5
Toluene
ND
ug/l
1 05/26/99
108-88-3
1,3-Dichloropropylene
ND
ug/l
1 05/26/99
10061-01-5
1,1,2-Trichloroethane
ND
ug/t
1 05/26/99
79-OD-5
Tetrechlcroethylene
ND
ug/t
1 05/26/99
127-18-4
Chlorobenzene
ND
ug/1
1 05/26/99
108-90-7
Ethylbenzene
ND
ugrt
1 05/26/99
IOD-41-4
1,3-Dichlorobenzene
ND
ug/l
1 05/26/99
541-73-1
1,4-Dichtcrobenzene
ND
ug/l
1 05/26/99
106-46-7
1,2-Dichlorabenzene
No
ug/t
1 05/26/99
95-50-1
1,2,4-Trichlorobenzene
No
ug/t
1 05/26/99
120-82-1
Naphthalene
ND
ug/t
1 05/26/99
91-20-3
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc

RECE ED
JUN 1 b i999
6;ENTRAL. FILES

n
Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
Pace Analytical Minneapolis, MN 55414
Tel: [phone]
Fax. [phone]
DATE: 06/03/99
PAGE: 2
Pace Project Nuclear: 1014585
Client Project to: 5705
Pace Sample No: 101276897
Date
Collected: 05/18/99 Matrix: Water
Client Semple to: Opt OUTFALL
Date
Received: 05/19/99
Peremeters
Results
Units
.........
PRL
..........
Analyzed Analyst CAS# Footnotes
........ ..... ....................
.................................
Acrylanitrite
..........
NO
ug/t
10
05/26/99 107-13-1
Oibramofluoromethane (S)
115
%
05/26/99 1868-53-7
toluene-d8 (S)
123
%
05/26/99 2037-26-5
4-Broneflucrobenzene (S)
112
%
05/26/99 460-00-4
1,2-Dichlaroethane-d4 (S)
112
%
05/26/99 17060-07-0
GC/MS Semivoleti Les
SemivoLatiLe Organics
Method: EPA 8270
Prep
Method: EPA 3520
Phenol
ND
ug/L
10
05/27/99
LAN
108-95-2
2-ChlorophenoL
ND
ug/1
10
05/27/99
LAN
95-57-8
1,3-Oichlorobenzene
ND
u9/1.
10
05/27/99
LAN
541-73-1
1,4-Dichtorobenzene
ND
ug/L
10
05/27/99
LAN
106-46-7
1,2-Dichlarobenzene
ND
ug/l
10
05/27/99
LAN
95-50-1
2-Methylphenot
ND
ug/L
10
05/27/99
LAN
95-48-7
Nitrobenzene
ND
ug/t
10
05/27/99
LAN
98-95-3
2-Nitrophenol
ND
ug/t
10
05/27/99
LAN
88-75-5
2,4-DinethylphenoL
NO
ug/1
10
05/27/99
LAN
105-67-9
2,4-Dichlorophenol
NO
ug/L
10
05/27/99
LAN
120-83-2
1,2,4-Trichlarobenzene
NO
ug/t
10
05/27/99
LAN
120-82-1
Naphthalene
NO
ug/t
10
05/27/99
LAN
91-20-3
Mexachtorobutediene
No
ug/l
10
05/27/99
LAN
87-68-3
DinethyLphthalate
RD
ug/t
10
05/27/99
LAN
131-11-3
2,6-Oinitrotoluene
ND
ug/1
10
05/27/99
LAN
606-20-2
Acenaphthylene
ND
ug/L
10
05/27/99
LAN
83-32-9
2,4-Dinitrophenol
ND
ug/l
51
05/27/99
LAN
51-28-5
4-Nitrophenol
ND
ug/L
51
05/27/99
LAN
100-02-7
2,4-Oinitroto Were
ND
ug/L
10
05/27/99
LAN
121-14.2
DiethyLphthaLate
ND
ug/L
10
05/27/99
LAN
84-66-2
Ftuorene
ND
ug/L
10
05/27/99
LAN
86-73-7
4,6-Dinitro-o-cresol
ND
ug/t
51
05/27/99
LAN
534-52-1
NezechLorobenzene
ND
ug/L
10
05/27/99
LAN
118-74-1
Phenenthrene
ND
ug/t
10
05/27/99
LAN
85-01-8
Anthracene
ND
ug/L
10
05/27/99
LAN
120-12-7
Di-n-butyLphthalate
1.7
ug/L
10
05/27/99
LAN
84-74-2
Ftuoranthene
ND
ug/L
10
OS/27/99
LAN
206-44-0
Pyrene
ND
ug/L
10
05/27/99
LAN
129-00-0
Senzo(a)anthracene
ND
ug/L
t0
05/27/99
LAN
56-55-3
Chrysene
ND
ug/L
10
05/27/99
LAN
218-01-9
b1s(2-EthylhexyL)phthalete
12
ua/L
10
05/27/99
LAN
117-81-7
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except to full,
without the written consent of Pace Analytical Services, Inc.

RECEIVE[)
JUN 1 6 1999
r,carre��. FILES

Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
Pace Analytical Minneapolis, MN 55414
Tel: [phone]
Fax [phone]
DATE: 06/03/99
PAGE: 3
Pace Project Number: 1014585
client Project ID: 5705
Pace Seaple No: 101276897
pate
Collected: 05/18/99
Matrix:
Water
client Saaple t0: 001 WTFALL
Date Received: 05/19/99
Parameters -
Results
Units
PRL
------'---
Analyzed
--------
Analyst
-----
CASH Footrxltes
......... ----------
---------------------------------
3,4-Benzofluorenthene
----------
ND
---------
uB/l
10
05/27/99
LAN
205-99-2
2
eenzo(k)fluoranthene
ND
u5/l
10
05/27/99
LAN
207-08-9
2
eenzo(a)pyrene
ND
u5/l
10
05/27/99
LAN
50-32-8
Hexachloroethane
ND
u5/l
10
05/27/99
LAN
67-72-1
Nitrobenzene-d5 (S)
105
%
05/27/99
LAN
4165-60-0
2-Fluorobiphenyl (S)
634
X
05/27/99
LAN
321-60-8
3
TerphenyL-d14 (S)
529
%
05/27/99
LAN
1718-51-0
3
Phenol-d6 (S)
27
%
05/27/99
LAN
13127-88-3
3
2-Fluorophenot (S)
102
it
05/27/99
LAN
367-12-4
2,4,6-Tribromophemwl (a)
410
%
05/27/99
LAN
118-79-6
3,4,5
Date Extracted
05/25/99
REPORT OF LABORATORY ANALYSIS
This report shell not be reproduced, except in full,
without the whiten consent of Pace Anayfical Services, Inc.

RECOVE D
JUN 9 6 1999
CENT AL FILES

Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
D.�e.e Anse w4in �� Minneapolis, MN 55414
Tel: [phone]
Fax [phone]
DATE: 06/03/99
PAGE: 4
Pace Project Number: 1014585
Client Project to: 5705
Pace Seiryle No:
101276905
Date Collected: 05/18/99
Matrix: Water
Client Semple 10:
TRAVEL BLK
Date Recei Ved: 05/19/99
Parameters
"-------------------
Results Units
- ------ "------------.-----
PRL Analyzed Am tyat CAS#
......... -------- ---------------
Footnotes
---- --- - --
GC/MS Volatiles
8260 Lou Level H2O
Method: EPA 826D
Prep Method: EPA 826D
Methyl Chloride
ND
ug/l
1
05/26/99
74-87-3
Vinyl Chloride
ND
ug/l
1
05/26/99
75-01-4
Chloroethane
ND
ug/(
1
05/26/99
75-00-3
Methylene Chloride
No
ug/l
1
05/26/99
75-09-2
1,1-Dichloroethylene
ND
ug/l
1
05/26/99
75-35-4
1,2-trans-Dichloroethytene
ND
ug/l
1
05/26/99
156-60-5
1,1-Dichloroethene
ND
ug/t
1
05/26/99
75-34-3
Chloroform
ND
ug/l
1
05/26/99
67-66-3
1,1,1-Trichloroethane
ND
ug/t
1
05/26/99
71-55-6
Carbon Tetrachloride
ND
ug/l
1
05/26/99
56-23-5
Benzene
ND
ug/l
1
05/26/99
71-43-2
1,2-Dfchloroethane
ND
ug/t
1
05/26/99
107-06-2
Trichloroethyl me
NO
ug/l
1
05/26/99
79-01-6
1,2-Dich(oropropene
ND
ug/(
1
05/26/99
78-87-5
Toluene
ND
ug/L
1
05/26/99
108-88-3
1,3-Dichlorapropylene
ND
ug/t
1
05/26/99
10061-01-5
1,1,2-Trichloroethane
ND
ug/l
1
05/26/99
79-00-5
Tetrachloroethy(me
ND
ug/t
1
05/26/99
127-18-4
Chlorobenzene
ND
ug/t
1
05/26/99
108-90-7
Ethylbenzene
ND
ug/(
1
05/26/99
10D-41-4
1,3-Dichlorcbenzene
ND
ug/(
1
D5/26/99
541-73-1
1,4-Dichlorobenzene
ND
ug/1
1
05/26/99
106-46-7
1,2-Dichlorobenzene
No
ug/l
1
05/26/99
95-50-1
1,2,4-Trichlorobenzene
ND
ug/t
1
05/26/99
120-82-1
Naphthalene
ND
ug/t
1
05/26/99
91-20-3
Acrylonftrfle
ND
ug/l
10
05/26/99
107-13-1
Dibromofluorosethme (S)
114
%
05/26/99
1868-53-7
Toluene -de (S)
116
%
05/26/99
2037-26-5
4-Bramofluorobenxme (S)
108
%
05/26/99
460-00-4
1,2-Dich(oroethane-d4 (S)
111
It
05/26/99
17060-07-0
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

RECEN D
JUN 9 G 1999
(,r.,N7'rML FILF:ti

n n
Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
Gn nea Anal\A+Il SaMinneapolis, MN 55414
Tel: [phone]
Fax: [phone]
DATE: 06/03/99
PAGE: 5
Pace Project N..be,: 1D14585
Client Project ID: 5705
PARAMETER FOOTNOTES
ND Not Detected
NC Not Calculable
PRL Pace Reporting Limit
(a) Surrogate
[1) Detected but below the PRL; therefore, result is an estimated concentration (CLP J-Flag).
[2I No internal standard response observed for this compound.
133 The surrogate recovery was outside QC acceptance limits due to matrix interference.
143 Internal standard recoveries confrimed by reanalysis.
[51 Internal standard recoveries outside of method criteria. Not enough sample for re -extraction to prove matrix effect.
REPORT OF LABORATORY ANALYSIS
This report shall not be reProduced, except in full,
without the written consent of Pace Analytical Services, Inc.

n n
RECOVED
JUN 16 i999
CENTRAL FILES

Pau Analytical Services, Inc.
1700 Elm Street - Suite 200
Para Anawtit-cJ Minneapolis, MN 55414
BASF CORPORATION
Sand Hill Road
Enka, NC 28728
Attn: Mr. Ray Ackermen
QC Batch 10: 25111
Analysis Method: EPA 8270
Associated Pace Seri
METHOD BLANK: 101286300
Associated Pace Samples:
Parameter
Phenol
2-Chlorophenot
1,3-Dichlorobenzene
1,4-0ichlorobenzene
1,2.Dichtorobenzene
2-Methylphenol
Nitrobenzene
2-Nitrophenol
2,4-Dimethylphenol
2,4-Dichlorophenol
1,2,4-Trichtorobenzene
Naphthalene
Nexechtorobutediene
Dimethylphthatate
2,6-Dinitrototume
Acenephthytene
2,4-Dinitrophenol
4-Nitrophenol
2,4-Dinitrat0l uene
Diethylphthatate
Fluorene
4,6-Dinitro-o-cresol
Hexachlarobenzene
Phenenthrene
Anthracene
Tel: [phone]
Fax: [phone]
DUALITY CONTROL DATA DATE: 06/03/99
PAGE: 6
Pace Project Nunber: 10145BS
Client Project ID: 5705
OC Batch Method: EPA 352D
Analysis Description: Serivoletile Organics
101276897
101276897
Method
Blank
Units
Result
PRL Footnotes
.......... ..........
..........
ug/t
..........
ND
10
ug/I
NO
10
ug/t
ND
10
ug/t
NO
10
ug/l
ND
10
Wt.
No
10
ug/I
ND
10
ug/l
ND
1D
ug/I
NO
10
ug/t
NO
10
ug/I
ND
10
ug/I
ND
10
ug/I
ND
10
ug/t
ND
10
ug/I
ND
10
ug/t
NO
10
ug/L
NO
50
ug/l
NO
50
ug/t
No
10
ug/t
No
10
ug/L
ND
10
ug/t
ND
50
ug/I
NO
10
ue/I
ND
10
ug/I
ND
10
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

RECEIVED
JUN 1 6 1999
CENTRAL. FILES

n (�
Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
Para Analytical Minneapolis, MN 56414
Tel: [phone]
Fax: [phone]
DUALITY CONTROL DATA DATE: 06/03/99
PAGE: 7
Pace Project Number: 1014585
Client Project ID: 5705
METHOD BLANK: 101286300
Associated Pace Samples:
101276897
Method
Blank
Parameter
Units
..........
Result
..........
.... I .........................
Di-n-butylphthalate
ug/t
ND
Fluoranthene
ug/t
ND
Pyrene
ug/l
ND
Benzo(a)enthracene
ug/L
ND
Chrysene
ug/L
ND
bis(2-Ethylhexyl)phthalate
ug/l
ND
3,4-Senzofluoranthene
ug/l
ND
Benzo(k)fluoranthene
ug/l
ND
Renzo(a)pyrene
ug/l
ND
Nexachloroethene
ug/l
ND
Nitrobenzene-d5 (S)
%
S6
2-Fluorobiphenyl (S)
%
97
TerpheYyL-d14 (S)
%
116
Phenol-d6 (5)
%
99
2-Fluorophenol (S)
%
110
2,4,6-Tribr.phenol (5)
is
123
PRL Footnotes
10
10
To
10
10
10
10
10
10
10
LABORATORY CONTROL SAMPLE 8
LCSD: 101286318
101286326
Spike
LCS
Parameter
Units
----- ----
Con..
-------
Result
------
------------------------------
Phenol
ug/t
50
35.24
2-Chlorophenol
ug/1
50
37.75
1,3-Dichtorobenzene
ug/l
50
36.97
1,4-Dichlorobenzene
ug/t
50
36.69
1,2-Dichlorebenzene
ug/t
50
36.69
2-11ethylphernot
ug/t
50
39.54
Nitrobenzene
ug/t
50
38.33
2-Nitrophenol
ug/t
50
40.48
2,4-Di methytpheoot
ua/t
Su
36.98
2,4-Dichlorophenot
ug/1
50
42.76
1,2,4-Trichlorobenzene
ug/t
50
40.34
Naphthalene
us/t
50
39.92
Rexachlorobutediene
ug/t
50
40.44
DinethytphthaLate
ug/t
50
42.67
2,6-Dinitrotoluene
ug/t
50
42.73
Acenaphthene
ug/t
5D
42.71
Spike
Spike
LCSD
Dup
% Re.
Result
% Rec
RPD
... ..
70.5
..........
41.98
... I-
84.0
-----
17
75.5
43.39
86.8
14
73.9
43.10
86.2
15
73.4
42.96
85.9
16
73.4
42.85
85.7
15
79.1
42.93
85.9
8
76.7
44.95
89.9
16
81.0
48.46
96.9
18
74.0
17.88
35.8
70
85.5
48.73
97.5
13
80.7
47.25
94.5
16
79.8
46.24
92.5
15
80.9
47.22
94.4
15
$5.3
46.09
92.2
8
85.5
46.52
93.0
8
85.4
47.02
94.0
10
Footnotes
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

RECEIVED
JUN 1 6 1999
CENTRAL FILES

Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
pore Onawtira1 Minneapolis, MN 55414
Tel: [phone]
Fax:6*617-6444
DUALITY CONTROL DATA DATE: 06/03/99
PAGE: 8
Pace Project Nurber: 1014585
Client Project IDz $705
LABORATORY CONTROL SAMPLE 8
LCSD: 101286318
101286326
Spike
Spike
LCS
Spike
LCSD
Dup
Parameter
Units
Conc.
Result
x Rec
.....
Result
..........
% Rec
..........
RPD
..............................
2,4-Dinitrophenol
..........
ug/l
.................
50
46.06
92.1
52.17
104
12
4-Nitrophenol
ug/1
50
38.12
76.2
42.19
84.4
10
2,4-Dinitrotoluene
ug/l
50
42.03
84.1
46.14
92.3
9
Viethylphthalete
ug/L
50
43.02
86.0
46.64
93.3
8
Fluorene
ug/l
50
42.66
85.3
47.25
94.5
To
4,6-Dinitro-o-cresol
ug/l
50
47.85
95.7
52.54
105
9
Nexachlorobenzene
ug/l
50
44.60
89.2
48.15
96.3
8
Phenonthrene
ug/l
50
45.11
90.2
48.68
97.4
8
Anthracene
ug/l
$0
43.57
87.1
47.78
95.6
9
Di-n-butylphthalate
ug/l
50
46.34
92.7
48.21
96.4
4
FLuorenthene
ug/l
50
43.29
86.6
46.14
92.3
6
Pyrene
ug/l
50
48.63
97.3
49.82
99.6
2
Benzo(e)enthrocene
ug/t
50
45.15
90.3
49.46
98.9
9
Chrysene
ug/t
50
48.53
97.1
48.44
96.9
0
bis('-Ethylhexyl)phthalate
ug/t
50
48.05
96.1
52.74
105
9
3,4-Benzofluoranthene
ug/t
50
41.96
83.9
47.92
95.8
13
Benzo(k)fluoranthene
ug/l
50
44.16
66.3
48.68
97.4
10
Benzo(e)pyrene
ug/l
50
42.64
85.3
46.77
93.5
9
Nexachloroethane
ug/l
50
38.30
76.6
44.17
88.3
14
Nitrobenzene-d5 (S)
81
90
2-Fluorobiphenyl (S)
90
97
Terphenyl-dl4 (S)
96
100
Phenol-d6 (S)
95
105
2-Fluorophenol (S)
102
112
2,4,6-Tribramophenol (S)
121
123
Footnotes
----------
2
2,2
2
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except In full,
without the written consent of Pace Analytical Services, Inc.

V: EEc NE
JUN 16 1999
(,F,M RAI. FlU-S

Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
Dann Ano��A4ig+�� Minneapolis, MN 55414
BASF CORPORATION
Sand Fill Road
Enka, NC 28728
Attn: Mr. Ray Ackerman
OC Batch ID: 25160
Analysis Method: EPA 8260
Associated Pace Samples:
METHOD BLANK: 101288231
Associated Pace Ronales:
Parameter
MethyL Chloride
Vinyl Chloride
Chloroethane
Methylene Chloride
1,1-DiChloroethylene
1,2-tram-DichLoroethylene
1,1-Dichloroethane
Chloroform
1,1,1-Trichloroethene
Carbon Tetrachloride
Benzene
1,2-Dichloroethane
Trichloroethylene
1,2-Dich Loropropane
Toluene
1,3-Dichloropropene
1,1,2-Trich Loroethane
Tetrachloroethylene
Chtorobenzene
Ethytbenzene
1,3-DichLorobenzene
1,4-Dichlorobenzene
1,2-Dichlorobenzene
1,2,4-Trich Lorobenzene
Tel: [phone]
Fax: [phone]
QUALITY CONTROL DATA DATE: 06/03/99
PAGE: 9
Pace Project Number: 1014585
Client Project 1O: 5705
GC Batch Method: EPA 8260
Analysis Description: 8260 Lou Level H2O
101276897 101276905
101276897
Units
ug/I
ug/I
ug/I
ug/L
up/t
ug/l
ug/L
ug/I
ug/I
ug/I
u9/I
us/I
us/I
ug/I
ug/L
ug/t
u9/l
ug/t
ug/l
ug/l
Gg/t
us/I
ug/I
u9/I
ID1276905
Method
Blank
Result
ND
ND
ND
ND
No
ND
ND
ND
No
No
ND
ND
ND
ND
ND
ND
ND
No
NO
No
No
No
ND
No
1
1
1
1
1
1
1
1
1
i
i
1
1
1
1
1
1
1
1
1
1
i
1
1
PRL Footnotes
......... ..........
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

RECEIVED
JUN 1 6 1999
CENTRAL FILES

Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
Dann Minneapolis, MN 55414
METHOD BLANK: ID12SB231
Associated Pace SM1Pi--1
101276897
Parameter Units
Naphthalene
ug/t
Acrytonitrile
ug/t
Dibromefluoromethane (S)
%
Toluene-& (S)
%
4-Brornofluorobenzene (S)
%
1,2-Dichloroethane-d4 (S)
%
QUALITY CONTROL DATA
101276905
Method
Blank
Result PRL
ND
1
No
10
113
123
Ito
112
Tel:[phone]
Fax: [phone]
DATE: 06/03/99
PAGE: 10
Pace Project Nudoer: 1014585
Client Project ID: 5705
Footnotes
LABORATORY CONTROL SAMPLE B
LCSD: 101288249
101288256
Spike
Spike
LCS
Spike
LCSD
Dup
Parameter
Units
Conc.
Result
----------
% Bee
-----
Result
----------
% Rae
-----
RPD Footnotes
---------------
-- --------------------- -------
Methyl Chloride
----------
ug/t
-------
5.000
4.101
82.0
4.796
95.9
16
Vinyl Chloride
ug/t
5.000
4.124
82.5
4.882
97.6
17
Chtoroethene
ug/l
5.000
4.773
95.5
5.724
114
18
Methylene Chloride
ug/t
5.000
4.459
89.2
5.227
105
16
1,1-Dichlorcethylene
ug/l
5.000
3.719
74.4
4.544
90.9
20
1,2-trans-Dichlorcethylene
ug/t
5.000
3.684
73.7
4.457
89.1
19 3
1,1-Dichloroethene
ug/l
5.000
4.217
84.3
4.931
98.6
16
Chloroform
ug/l
5.000
4.285
85.7
5.160
1D3
18
1,1,1-Trfchloroethene
u9/1.
5.000
4.221
84.4
5.109
102
19
Carbon Tetrachloride
ug/l
5.000
4.038
$0.8
5.003
100
21
Benzene
ug/t
5.000
4.061
81.2
4.878
97.6
18
1,2-Dichloroethene
ug/l
5.000
4.375
87.5
4.991
99.8
13
Trichtoroethylene
ug/t
5.000
3.961
79.2
4.850
97.0
20
1,2-Dichioropropane
ug/t
5.000
4.184
83.7
4.932
98.6
16
Toluene
ug/l
5.000
4.D88
81.8
4.904
98.1
18
1,3-Dichtorepropylene
ug/t
5.000
4.004
80.1
4.810
96.2
18
1,1,2-Trichloroethane
ug/l
5.000
5.144
103
6.145
123
18
Tetrechloroethylene
ug/l
5.000
4.156
83.1
4.903
98.1
17
Chlorobenzene
us/1
5.000
4.148
83.0
4.937
98.7
/7
Ethylbenzene
u9/1.
5.000
4.192
83.8
5.079
102
20
1,3-Dfchlorobenzme
ug/l
5.000
4.156
83.1
5.003
100
18
1,4-Dichlarobenzene
ug/l.
5.000
4.033
80.7
4.912
98.2
20
1,2-Dichlorobenzene
ug/l
5.000
4.082
81.6
4.904
98.1
18
1,2,4-Trichlorobenzene
ug/t
5.000
3.036
60.7
3.885.
77.7
25 3
Naphthalene
ug/t
5.000
2.806
56.1
3.745
74.9
29
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

RECEIVED
JUN 16 1999
CENTRAL FILES

Pace Analytical Services, Inc.
1700 Elm Street -Suite 200
Dnnn MlnneapDIIS, MN 55414
QUALITY CONTROL DATA
LABORATORY CONTROL SAMPLE 5
LCSD: 101281
101288256
Spike
LCS
Parenexer
Unite
---------- ____------
Cone.
.-.....
Result
.....
-------------------_
Acrytonitrile
ug/t
25
43.06
DibroroFluor one there (5)
Toluene-d8 (S)
4-Broeoftuorobenxene (S)
1,2-Dichlor0ethane-d4 (S)
Tel: [phone]
Fax: [phone]
DATE: 06/03/99
PAGE: 11
Pace Project Number: 1014585
Client Project ID: 5705
Spike
Spike LCSD Dup
% Roe Result Is See RPD Footnotes
--------------- ----- ----- ----------
172 49.36 197 14
1% 113
120 120
111 110
108 109
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except In full,
without the written consent of Pecs Analytical Services, Inc.

RECEIVED
JUN 16 1999
CENTRAL FILES

Pace Analytical Services, Inc.
1700 Elm Street - Suite 200
Dann Annlv4ir �I Minneapolis, MN 55414
Tel: [phone]
Fax: [phone]
DATE: 06/03/99
PAGE: 12
Pace Project Number: 1014585
Client Project To: 5705
DUALITY CONTROL DATA PARAMETER FOOTNOTES
Consistent with EPA guidelines unrounded concentrations are displayed and have been used to calculate % Rec and RPD values.
ND Not Detected
NC Not Calculable
PRL Pace Reporting Limit
RPD Relative Percent Difference
(a) Surrogate
113 The surrogate and/or spike recovery was outside acceptance limits.
[2) Detected but below the PRL; therefore, result is an estimated concentration (CLP J-Flag).
[31 Spiked sample recovery is not within control limits.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except In full,
without the written consent of Pace Analytical Services, Inc.

RECEIVED
JUN 16 1999
CENTRAL FILES

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
WATER QUALITY SECTION
- March 15, 1999 -
Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Subject: Performance Audit Inspection
( Inspection Rating 11B-Minus"
n\� Wastewater Treatment Program
BASF Corporation
NPDES Permit Number NC0000299
` Buncombe County, North Carolina
Dear Mr. Dellinger:
The Performance Audit Inspection (PAI) that Gary
Francies and I conducted on February 18, 1999, of BASF's
wastewater treatment program resulted in an overall rating of
B-Minus relative to the evaluation of sampling, flow
measurement, and laboratory procedures. Regulatory and
methodology violations were.. identified in the laboratory
portion of the inspection which basically centered around
handling of chlorinated samples for ammonia and fecal
coliform analysis. Additionally, documentation of drying
times for the total suspended residue analysis together with
BCD seed correction and dilution problems need to be
addressed. Comparison of results of split sample analysis
between the BASF laboratory and the NCDENR Water Quality
laboratory show concerns which need to be further evaluated.
The results of this PAI should not be interpreted to
question compliance with terms and conditions contained in
the NPDES permit. Sample analysis showed the discharge to be
meeting effluent limitations and the evaluation of the
wastewater treatment facility showed proper operation and
control. The high total suspended residue concentration
tentatively attributed to the presence of finishing oils in
the wastewater stream is of concern as it approached the
daily maximum effluent limitation. The source of the high
total suspended residue concentration should be located and
addressed.
INTd........'LOINO, OR WOO. FIN PIP.., I...V1LLO. NC 18801-2414
PNONA 820.2......0 FAX 828.251-E482
AN EQUAL OPPORTUNITY /AFPI RMATIVI ACTION EMPLOYER -50% RECYCLED/I 0% P09T-CONSU MKR PAPER
=K a' 5'ir playm-

Page 2
Mr. Dellinger
A copy of the report is attached for your review. If you have
questions regarding this report, please do not hesitate to contact
Mr. Francies or me at [phone]
xuLY tr ly
L. He er
Environmental Chemist
Enclosure
cc: Melinda Greene, EPA
Forrest R. Westall
Gary Francies

�
r.
C
§/
r
E000
c22
|
!
!
,
`
\
if;lf«ifl=fil;i,«
\\
\�
(Z2
fiff>)tif;
!]i}!:{);/
-
!;02!!1ll!u
;<:f

OE)
2 �o
CY
:§
ƒ;�|§
7§§og
§ z ZO
�
H d\D50
5
_
?
!�
�
;---;.-;----w-
|
z�
�)|!
/),[§§•�`
!!!!!!!!!|
-
§/
g
|
IL
\
`!
)
!�
,!
.
�
\
(|
§
.§
!
!
!
/
LA
i
.
!
.

A United States nmental Protection Agency
Form Approved
W-D.-n, D.C. 20460
OMB No. 2040-0003
Approval Expires 7-31-85
CPA NPDES Compliance Inspection Report
Section A: National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector Far, Type
1 IN 1 215 1 3 1 NC0000299 11 12 99/02/18 17 18 Lq j 19 $ 20[Zj
uu a u u
Remarks
Reserved Facility Evaluation Rating BI CA Reserved
80
6769 70 In 71 on72u7374 75 LLL-LLJ
Section B: Facility Date
Name and Location of Facility Inspected.
Entry Time
Permit Effective Date
BASF CORPORATION
0830 HRS
90/10/01
US.HWY 19/23 & NC 112
Exit Time/Date
Permit Expiration Date
ENKA, NC, BUNCOMBE COUNTY
1530 HRS
95/09/30
Name(s) of On -Site Representative(sT/Title(s)
Phone N.B)
RAY C. ACKERMAN, ORC
[phone]
MANAGER, ENVIRONMENTAUSAFETY/QUALITY
Name, Address of Responsible Official
Title
JACK A. DELLINGER
GENERAL MANAGER
BASF CORPORATION
Phone No. Congaed
EN.C. 28728
[phone] NONKA,
Section C: Areas Evaluated During Inspection CODESv S-Satisfactory M-Marginal U- Unsatisfactory N- Not evaluatedsNot applicable
S
Permit
Records/Repoas
Facility Site Review
S
Flow Measurement
Laboratory
Effluent/Receiving Were.
Pretreatment
Compliance Schedules
Self -Monitoring Program
$
Operations & Maintenance
Sludge Disposal
Other:
S
$
L4S
$
S
S
Section D: Summary of Findings/Commests (Anach additional sheets i/necessary)
EFFLUENT DATA (COMPOSITE) PERMIT LIMITS (MO AVE/WEEKLY AVE)
FLOW — 0.632 MGD 1.25 MGD
BOD, 5-DAY — 137 #/DAY (26 MG/q 136 #/DAY / 291 #/DAY
TSS — 527 #/DAY (6 MG/D 209 #/DAY / 565 #/DAY
FECAL COLIFORM —<10 /100ML (GRAB) 2001100MU 400/100ML
D.O. — 8.9 MG/L @ Il-C NOT LIMITED
pH — 7.90 6.0 / 9.0 (RANGE)
ZINC — NS 3.65 #/DAY / 643.5 UCJL -
THE W WTP WAS IN FULL OPERATION. WITH ALL UNITS APPEARING IN GOOD WORKING QRDER.. ONE OF THE TWO CLARIFIERS (SOUTH CLARIFIER)
WAS OUT OF SERVICE FOR ROUTINE CLEANING AND WEIR LEVELING. NO PROBLEMS WERE NOTED. SLUDGE WAS BEING HANDLED VIA THE FRAME
FILTER PRESS. WASTING 15 BASED ON THE FM RATIO AND THE VOLATILE SOLIDS (AERATION) WHICH IS MAINTAINED IN THE RANGE OF 1100 - 1200
MCA. THE FACILITY WAS PRODUCING AN EFFLUENT WHICH WAS EXTREMELY CLOUDY WITH HIGH TSS (THOUGHT DUE TO FINISHING OILS BEING
INTRODUCED BY THE MANUFACTURING PROCESS). DISINFECTION 15 BEING PERFORMED BY USE OF A BROMO-CHLORO-DIMETHYDANTOIN TABLET
SYSTEM WHICH WAS PLACED IN USE THIS PAST YEAR. THE DISCHARGE WAS IN COMPLIANCE WITH DAILY MAXIMUM PERMIT LIMITS.
Names) and Signature(s) o Imp torts)
Agency/Offce/Telephone
Date
MAX L. HANER .-7
DWQ/ARO 828-251-6208
Sig ture of Revver
Agency/Office
Datgy
DWQ/ARO 828-251-6208
9
i
Regulatory Office Use Only
Action Taken 'Date
Compliance Status
7;Compliance
Noncompliance
Complianceen

n
n
PERFORMANCE AUDIT INSPECTION
WASTEWATER TREATMENT FACILITY (NC0000299)
BASF CORPORATION
ENKA, NORTH CAROLINA
FEBRUARY, 1999
INTRODUCTION
On Thursday, February 18, 1999, the North Carolina Division of
Water Quality conducted an on -site inspection of BASF's
wastewater treatment program including evaluation of the
laboratory and sample collection procedures.
The Performance Audit Work with the Company's laboratory was
conducted by Gary Francies and Max Haner of the Division's
Asheville Regional Office. Personnel from BASF Fibers were Ray L.
Ackerman, Manager, Environmental/Safety/Quality and Operator in
Responsible Charge (ORC) of the wastewater treatment facility;
Kay Crowder, Maintenance Superintendent and backup operator; Don
Canipe & Don Wilkey, electrician; Ross Peebles, laboratory; and
Eric Barbour, Site Facilities.
The purpose of this inspection was to determine the quality of
the self -monitoring program being conducted by BASF Fibers
Corporation and assess the reliability of its reported data.
The inspection consisted of evaluation of the flow monitoring
equipment and data handling, evaluation of sample collection and
preservation techniques and evaluation of laboratory and
analytical techniques, record keeping and data reporting.
procedures.. NPDES-permit number NC0000299 provides for a
discharge (001) from the Company's wastewater treatment facility;
two equalization basins (series),an aeration basin, dual final
clarifiers, achlorine contact chamber, a mixing lagoon, sludge
handling and disposal (thickener, conditioner, filter press, BASF
landfill as cover) with discharge to Hominy Creek, Class "C"
waters in the .French Broad River Basin.. Additionally,. the permit
provides for a discharge (002) of non -contact cooling water from
a barometric condenser into Hominy Creek via the east ditch on
BASF property.
BASF Fibers Corporation is conducting the self -monitoring part of
this program in accordance with monitoring requirements contained
in NPDES Permit Number NC0000299. Flow measurement, composite
sampling and collection of samples is satisfactory. Violations
were found, however, with the laboratory methodology which
addressed sample preservation (and documentation) for chlorinated
samples for ammonia and fecal coliform analysis. Additional
violations were noted in documentation of drying ,times. for total
suspended residue sample analysis and seed correction and
dilution practices in the SOD sample analysis. As result,
the overall PAI rating for this facility is B-Minus. A PAI
rating sheet is attached.

. �� n
Page 2
1999 PAI Report
BASF Corporation Wastewater Treatment Facility
FINDINGS AND RECOMMENDATIONS
Recommendations contained in this section ill appear as
regulatory requirements to correct deviations or as suggestions
to strengthen the self -monitoring and laboratory program.
A. FIELD EVALUATION
1 . - FLOW MEASUREMENT: Flow is measured at the 001
discharge structure in the final mixing lagoon using a
30-inch cipolletti weir with a Miltronic ultrasonic
depth probe and Honeywell Recorder. Accuracy of this
unit including the integrity of the work is checked
weekly, The unit is checked for accuracy during zero
flow periods when the level of the final basin is
lowered for maintenance. Last calibration by Law
Engineering on 1/28/99. A check of the weir showed it
to be plumb, level, and meeting requirements for a
properly installed cipolletti weir. Additionally,
instantaneous flow measurement at the weir compared
with instrumentation recordings showed a difference of
approximately 7.6%, well within the allowable 10%
difference.
a. RECORDS: Records are maintained in a hardbound
notebook by Don Canipe, maintenance (electrician).
Mr Canipe was assisted by Don Wilkey.
b. DATA HANDLING: Flow totalizer measurements are
handling properly.
2. SAMPLING PROCEDURES: The effluent' composite
sampling device for discharge 001 is an ISCO model
371OR unit with refrigeration. The permit requires no
monitoring of discharge 002.
a. Effluent 24 hours composite samples are collected
proportional to flow with a setting of 125 ml per
cycle. Each sampling cycle is approximately 5,000
gallons. Two separate measurements showed the actual
sample aliquot to be. 124 ml and 120 ml.
b. Pump and sample tubing last was replaced in
October, 1998. Tubing is checked routinely and
replaced as necessary. The. sample strainer was in need
of cleaning.

Page 3
1999 PAI Report
BASF Corporation Wastewater Treatment.Facility
- C. Records: The volume of each composite sample is
measured and recorded. .These records also should
include the temperature of each composite sample upon -
collection.
3. FIELD MEASUREMENTS:
a. The effluent dissolved oxygen (D.O.) measurement
is measured daily during the time the composite
sample is collected for analysis using a D.O. meter
and probe. D.O. measurement of the discharge was
8.9 mg/l ® 11° C (NCDWQ).
b.. The effluent pH measurement is performed in the
laboratory from a grab sample collected from the
discharge during sample pickup. The pH was measured at
7.90 s.u. (NCDWQ).
C. The effluent total residual chlorine concentration
is measured in the laboratory from a grab sample
collected from the discharge during sample pickup.
The total residual chlorine was measured at 0.11 mg/l
(NCDWQ).
4. SAMPLE HANDLING: The composite sample (carboy)
was properly handling with the sample being thoroughly
mixed prior to transfer to the sample container(s).
5. RECORD MAINTENANCE: Preventative maintenance
work performed on the system was in accordance with.
needs addressed in the weekly computer printout.
Calibration records for the dissolved oxygen sensors in
the aeration basin should be maintained. Time of
..operation records for the solids handling system need
to be maintained.
6. OPERATION & MAINTENANCE: O&M is being performed
in a satisfactory with interest on preventative. The
south clarifier was being cleaned and its weir was
being leveledduringthis inspection. Wasting of
solids based on F/M ratio and volatile solids in the
system (target 1100-1200 mg/1).. _
7. PERMIT VERIFICATION: The facility is operating
in compliance with terms and conditions contained in
the NPDES permit (NC0000299). The permit accurately
reflects the existing wastewater treatment facility and
discharge location.

Page 4
1999 PAI Report
BASF Corporation Wastewater Treatment Facility
B. LABORATORY EVALUATION
1. PERSONNELL: All NPDES testing performed at this
facility is under supervision of Ray Ackerman. The manager
of the laboratory is Jack Dellinger, PhD. -
2. FACILITIES AND EQUIPMENT: The laboratory is
spacious and adequately equipped for testing performed at
this location of this faciltiy. The laboratory routinely
conducts tests for pH, SOD, Total Suspended Residue, Fecal
Coliform, Ammonia, Zinc, Total Residual Chlorine, and
Temperature. The BASF laboratory is state certified for the
above parameters. Pace Laboratories, Inc., performs the
remaining NPDES analyses including Aquatic Toxicity.
A new spectrophotometer has been obtained by BASF since the
last inspection for ammonia analysis.
3. METHODOLOGY: All testing procedures are based upon
EPA's approved methodology or the Laboratory Certification
Regulation; 15A NCAC 2H.0800. Violations are entered as
follows:
a. Violation - Sample Preservation
Dechlorination of both the ammonia sample or the fecal
coliform sample is not documented and therefore
considered asnot being performed>
Requirement: 15A NCAC 2H.0805(a)(1)&(7)(M)&(N)
requires in part that samples containing chlorine must
be dechlorinated at the time of sample collection and
treated according to the requirements of the anaklysis
to be performed. Upon receipt in the laboratory,
samples treated for chlorine must be checked and
documented to be free of chlorine.
b. Violation - Total Suspended Residue
The time that the sample is placed in the oven for
drying and the time that the sample is taken from the
oven is not being documented.
Requirement: 15A NCAC 2H.0805(a)(7)&(a)(7)(D)
.requires drying times be documented. -

Page 5
1999 PAI Report r
BASF Corporation Wastewater Treatment Facility
C. Violation - BOD
The seed correction factor must be in the range of
0.6 mg/l to 1.0 mg/l. Records indicate the seed
correction factor for this analysis was below thisI
range.
Requirement: STANDARD METHODS, 18TH Edition, Method
5210B.4d 2.
d. Violation - BOD
The dilutions used for seed control have been too low
to yield proper D.O. depletion and residual
requirements.
Requirement: STANDARD METHODS, 18TH Edition, Method
5210B.5 - requires that seed controls and samples must
have at least 2.0 mg/l D.O. depletion plus a residual
D.O. of 1.0 mg/l.
e. Violation - Method Quality Control requirements
not being met must be noted on the discharge monitoring
report (DMR).
Requirement: 15A NCAC. 2H.0805(a)(7)&(a)(7)(D)
4. RECORDS KEEPING:
Laboratory record keeping was consistent with good
laboratory practice. Records were complete and.well
detailed.
5. QUALITY CONTROL:
Effluent samples split with the BASF laboratory showed
the following comparison:
BASF LABORATORY DWQ LABORATORY
BODS 17.9 mg/l 26.2 mg/l
TSS 85 mg/l 102 mg/l
Non-efflesint. sample split only for compa4'tive purposes
FECAL COLT 520/100 ml 270/100 ml

Page 6
1999 PAI Report
BASF Corporation Wastewater Treatment Facility.
6. DATA HANDLING & REPORTING:
A review of discharge monitoring report (dmr) and
supporting data for August, October, and November,
1998, showed no data entry or dmr transfer problems.
The facility was transcribing data in a satisfactory
manner.

PAI RATING SCALE
Ra in General Description
A The facility has no problems with flow monitoring,
sampling, analyses or data calculating and reporting
procedures. The overall self -monitoring program and
the quality and reliability of the data reported to
state/federal agencies are excellent. The general
operation of the entire facility is also very good.
The facility has a few minor problems in one or more
areas of flow monitoring, sampling, analyses or data
calculating and reporting procedures. Examples include
infrequent calibration of flow monitoring equipment,
improper refrigeration of samples, slight discrepancies
in oven or incubator temperatures and not keeping
thorough records. The self -monitoring program is good
and the problems have no major impact on data
reliability. The overall operation of the facility is
very good.
The facility has a major or several minor problems with
flow monitoring, sampling, analyses or data calculating
and reporting procedures. Examples include
malfunctioning flow monitoring equipment, improper
sampling site, not dechlorinating fecal coliform samples,
unacceptable oxygen depletions and improper seed
correction factors in BOD analyses. The problems noted
at .the facility cause the reliability of some of the data
to be questionable. The general operation of the overall
facility is good.
D - -There are -major -problems with flow monitoring, sampling
analyses or data calculating and reporting procedures.
Examples include estimating flow, collecting samples at
wrong locations, using improper glassware or equipment,
malfunctioning laboratory equipment, poor laboratory
techniques, or errors in data calculations. The problems
cause the reliability of the self -monitoring data to be
highly questionable. The overall operation of the
facility is fair.
Severe problems with flow monitoring, sampling, analyses
or data calculating and reporting procedures cause the
self -monitoring data to be unreliable. Examples include
no flow monitoring capabilities, wrong sampling
frequencics and procedures, using unacceptable analytical
techniques or fabrication of information. The self -
monitoring program and the general operation of the
facility is poor. _

°
l
a
"
0
x
®�
U
pp
�
t
iw
U
S
S
S
S
S
S
c
rz
F
a
>
z
�
°
Zy
Y
♦pa9
{q
�E}yyp,
,aj
qy
�
F
Z
0
wQ
Y
N
3
epp
U
U
6l.
U
U
p
U
U
E.
LL
G
qq
i
11�
N
N
e
e
ems,
8
g�
F
E
8
fi
9
fi
B
9-
9
A
V'U
Y
q
a
M
F
W
u
9
O
d
6
Sa
C�j
IY
a
q
A
0
µ
a
�
o
a
a
N
eIt
E
F
E
% a
m-
a
�
m
B
H
6
�
F
6
-
6
K
O
X�
iF
2
Z
F
t
ss
�
P
N
M
"e
N

State of North Carolina
Department of Environment
and Natural Resources
Asheville Regional Office
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
0ax 4h
NCDENR
NORTNCAROLINADERARTIMENTOF
ENVIRONMENT
AND NI Ri RE$OURces
WATER QUALITY SECTION
Mr. Jack A. Dellinger, PhD
General Manager
BASF Corporation
Sand Hill Road
Enka, North Carolina 28728
Dear Mr. Dellinger:
March 9, 1998
Subject: Performance Audit Inspection
Inspection Rating "A -Minus"
Wastewater Treatment Program
BASF Corporation
NPDES Permit Number NC0000299
,,Buncombe County, North Carolina
r
The Performance Audit Inspection (PAI) that Mr. Gary Francies and I
conducted on February 19, 1998, of BASF's wastewater treatment program
resulted in an overall rating of A -Minus relative to the evaluation of
sampling, flow measurement, and laboratory procedures. A minor violation
of the laboratory certification regulations (15A NCAC 2H.0600) was noted
during the inspection.Specifically, the BOD bench worksheets should show
the time that each BOD set is removed from the incubator and each
worksheet should be initialed by the analyst. A copy of the report is
attached for your review.
The wastewater treatment facility is considered in full compliance
with terms and conditions contained in NPDES Permit Number NC0000299.
If you have questions regarding this report, please do not hesitate to
contact Mr. Francies or me at [phone].
7, u t y, -,
x L. Haner /,i
Environmental Chemist
Enclosure ,Ida Gla+^�
cc: Aege 1=10, EPA
Forrest R. Westall
Gary Francies
59 WDodtin Place, Asheville, North Carolina 28801
Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer

United State ironmental Protection Agency 7 Form Approved
Washington, D.C. 20460 OMB No. 2040-0003
EPA NPDES Compliance Inspection Report Approval Expires 7-31-85
Transaction Code NPDES yr/mo/day Inspect,ion Type Inspector Fac Type
1 u 2 3 NC0000299 111 12 98/02/19 17 18 LJ 19 u 20 u u I�I Remarks
Reserved Facility Evaluation Rating BI QA Reserved w
67 I I I69 70 l a ' 71 KI 72 I KI I 73 1 1 1 174 75 1 1 11 1 1 80
Name and Location of Facility Inspected
Entry Time
Permit Effective Date
BASF CORPORATION
0850 HOURS
95/12/01
US HWY 19/23 & NC HWY 112 (SAND HILL RD)
Exit Time/Date
Permit Expiration Date
ENKA, NC (BUNCOMBE COUNTY)
1545 HOURS
00/09/30
Name(s)of On -Site Representativels)/Title(s)
Phone No(s)
RAY C. ACKERMAN, ORC & MGR OF ENVIRONMENTAL SAFETY & QUALITY
(704) 667 -7277
KAY CROWDER/DON CANIPE
Name, Address of Responsible Official
Title
DR. JACK A DELLINGER
GENERAL MANAGER
BASF CORPORATION
Phone No.
Contacted
ENKA, N.C. 28728
(704) 667 - 7110
YES
Section C: Areas Evaluated During Inspection CODES w S
- Satisfactory M - Marginal U - Unsatisfactory
N - Not evaluated/Not applicable
S
Permit
Records/Reports
Facility Site Review
S
Flow Measurement
Laboratory
Effluent(Receiving Waters
Prten
ianceSchedules
Self -Monitoring Program
$
Operations & Maintenance
Sludge Disposal
Other
S
S
qm8Cmnp1'nt
$
S
S
D.O.
AMP
PH
LENT DATA 1
(COMPOSITE)
- 0.434
MGD
5-DAY
- 32.2
#/DAY (8.9 MG/H
- 21.7
#/DAY (6 MUL)
COLIFORM
- 8
/100ML (GRAB)
- 8.65
MG/L ® 12-C
3NIA
- <0.1
MG/L
- 7.45
- NS
PERMIT LIMITS (MO AVEIWEEKLY AVE)
1.25 MGD
136 #/DAY / 291 #/DAY
209 #/DAY / 565 #/DAY
200/100MU 400/100ML
NOT LIMITED
NOT LIMITED
6.0 / 9.0 (RANGE)
3.65 #/DAY / 643.5 UG/L
THE WWTP WAS IN FULL OPERATION. WITH ALL UNITS APPEARING IN GOOD WORKING ORDER., ONE OF THE TWO CLARIFIERS WAS OUT OF
SERVICE FOR ROUTINE O&M. NO PROBLEMS WERE NOTED. SLUDGE WAS BEING HANDLED VIA THE FRAME FILTER PRESS. WASTING 15 BASED ON THE
F/M RATIO AND THE VOLATILE SOLIDS (AERATION) WHICH 15 MAINTAINED IN THE RANGE OF 1300 - 1500 MCA. THE FACILITY WAS PRODUCING AN
EFFLUENT IN COMPLIANCE WITH PERMIT CONDITIONS. COMPLIANCE NOTED.
MAX L. HANEIi
DWQ/ARO 704-251-6208
Sip—r3719liewnsr Agency/Office Dale
DWQ/ARO 704-251-6208
Regulatory Office Use Only
Anion Taken Date Compliance Status
D Noncompliance
Compliance

n r�
PERFORMANCE AUDIT INSPECTION
WASTEWATER TREATMENT FACILITY (NC0000299)
BASF CORPORATION
ENKA, NORTH CAROLINA
FEBRUARY, 1998
INTRODUCTION
On Thursday, February 19, 1998, the North Carolina Division
of Water Quality conducted an on -site inspection of BASF's
wastewater treatment program including evaluation of the
laboratory and sample collection procedures.
The Performance Audit Work with the Company's laboratory was
conducted by Gary Francies and Max Haner of the Division's
Asheville Regional Office. Personnel from BASF Fibers were
Ray L. Ackerman, Manager, Environmental/Safety/Quality and
Operator in Responsible Charge (ORC) of wastewater treatment
facility; Kay Crowder, Maintenance Superintendent and backup
operator; Don Canipe, Electrician; and Ross Peebles,
laboratory.
The purpose of this inspection was to determine the quality
of the self -monitoring program being conducted by BASF Fibers
Corporation and assess the reliability of its reported data.
The inspection consisted of evaluation of the flow monitoring
equipment and data handling, evaluation of sample collection
and preservation techniques, and evaluation of laboratory
analytical techniques, record keeping and data reporting
procedures. NPDES Permit Number NC0000299 provides for a
discharge (001) from the Company's wastewater treatment
facility; two equalization basins (series), an aeration
basin, dual final clarifiers, a chlorine contact chamber
(disinfection currently not necessary), a mixing lagoon,
sludge handling and disposal (thickener, conditioner, filter
press, BASF landfill as cover) and a discharge (002) of non -
contact cooling water from a barometric condenser into Hominy
Creek, Class "C" waters in the French Broad River Basin via
the east ditch on BASF property.
BASF Fibers Corporation is conducting its self -monitoring
program in accordance with monitoring requirements contained
in NPDES Permit No. NC0000299. A minor regulatory violation
noted in the BOD procedure centered around failure of the
analyst to initial the bench worksheet and record the times
the samples were removed from the incubator. No other
violations were found during this inspection.
The overall PAI rating for this facility is "A -Minus". A PAI',
rating sheet is attached.

Page 2
1998 PAI Report
BASF Corporation Wastewater Treatment Facility
FINDINGS AND
Recommendations contained in this section will appear as
REGULATORY REQUIREMENTS to correct deviations or as
SUGGESTIONS to strengthen the self -monitoring and laboratory
program.
A. FIELD EVALUATION
1. FLOW MEASUREMENT: Flow is measured at the 001
discharge structure in the final mixing lagoon using a
30-inch Cipolletti weir with a Miltronic ultrasonic
depth probe and Honeywell Recorder. Accuracy of this
unit including the integrity of the weir is checked
weekly. The unit is checked for accuracy during zero
flow periods when the level of the final basin is
lowered maintenance. Lastcalibration by outside firm
(Law Engineering) 1/17/96. -
a. RECORDS: Records are maintained in a hardbound
notebook by Don Canipe, maintenance (electrician).
b. DATA HANDLING: Flow totalizer measurements are
handled properly.
2. SAMPLING PROCEDURES: The effluent composite sampling
device for discharge 001 is an ISCO model 3710R unit
with refrigeration. The permit requires no monitoring
for discharge 002.
a. Effluent 24 hour composite samples are
proportional with setting to collect an aliquot of
approximately 125 ml per cycle; approximately 20,000
gallon intervals. Actual measurement of this aliquot
was 120 ml.
b. SAMPLE EQUIPMENT - Pump and Sample Tubing was
replaced three times since the previous PAI inspection
(April, 1997).
c. RECORDS: The volume of each composite is measured
and recorded for preventative maintenance purposes.

n
Page 3
1998 PAI Report
BASF Corporation Wastewater Treatment Facility
2. SAMPLING PROCEDURES CONTINUED:
c. The temperature of the refrigeration unit is
checked regularly by measurement of the composite
sample during the time it is collected. Measurement is
performed via use of a dissolved oxygen meter with
records maintained in laboratory. A thermometer was
present in the refrigerator proper and a second
thermometer was present in the sample carboy.
The temperature of composite sample was 4°C. A
previous problem with warm -weather temperature
variations in this unit apparently was solved by using
a glass carboy.
3. FIELD MEASUREMENTS:
a. The effluent dissolved oxygen (D.O.) measurement
is measured daily during the time the composite
sample is collected for analysis with D.O. meter and
probe. D.O. measured 8.65 mg/l @ 120C (NC DWQ)
b. The effluent pH measurement is performed in the
laboratory from a grab sample collected from the
discharge during the time the composite sample is
collected. The pH measured 7.45 s.u.@ 13.2°C (NC DWQ)
4. SAMPLE HANDLING: The composite sample (carboy)
was properly handled. The sample was thoroughly mixed
prior to transfer to the sample container.
5. RECORD MAINTENANCE: Preventive maintenance work
preformed on system in accordance with weekly computer
printout. Records of all adjustments and corrections
to the sampling or flow measuring equipment are being
properly maintained.
6. OPERATION AND MAINTENANCE: O&M for all units of this
facility is satisfactory. The equalization basin and
digester were cleaned and repainted since previous PAI
inspection. Wasting of solids is based on the F/M
ratio and volatile solids in system (target: 1300 to
1400 mg/1). One of the two clarifiers were down for
routine repairs.

Page 4
1998 PAI Report
BASF Corporation Wastewater Treatment Facility
A. 7. PERMIT VERIFICATION: The facility is operating in
compliance with terms and conditions contained in
NPDES permit No. NC0000299. The permit accurately
reflects the existing wastewater treatment facility
and discharge location (001).
B. LABORATORY EVALUATION
PERSONNEL: All NPDES testing performed at this
facility is under supervision of Joann Henderson as
Administrative Supervisor and Ray Ackerman, Functional
Supervisor. The manager of the laboratory is Jack
Dellinger, PhD.
FACILITIES AND EQUIPMENT: The laboratory is spacious
and adequately equipped for testing performed at this
location for this facility. The laboratory routinely
conducts tests for pH, BOD 5 Total Suspended Residue,
Fecal Coliform, Ammonia, Zinc, and Temperature. The
BASF laboratory is state certified for these
parameters. The remaining NPDES analyses including
Chronic Toxicity are performed by Pace Laboratories,
Inc. (certified commercial laboratory). Lab equipment
appears well maintained.
3. METHODOLOGY:. All testing procedures are based upon
EPA's approved methodology the Laboratory
Certification Regulation; 15A NCAC 2H .0800.'
A minor regulatory violation was noted in the
procedure for handling bench worksheets during the
DOD analysis. (see below)
Of the 53 most recent BOD sets, 17 sets failed to show
the initials of the laboratory person analyzing the
sample and 22 failed to record the time the sample was
removed from the incubator.
The bench worksheet prepared during the BOD analysis
should include a record of the time that the sample
was removed from the incubator as well as the initials
of the analyst. REGULATORY REQUIREMENT -LABORATORY
CERTIFICATION REGULATION 15A NCAC 2H .0805 (a)(7)(H)

Page 5
1998 PAI Report
BASF Corporation Wastewater Treatment Facility
4. RECORDS KEEPING: Laboratory record keeping was
consistent with good laboratory practice.
Review showed data to appear accurate.
5. SAMPLE HANDLING AND PRESERVATION: All samples were
found to be collected and preserved and in accordance
with standard procedures.
6. QUALITY CONTROL:
Samples were split with BASF for comparative analysis
showed the following results:
BASF Laboratory
DOD, * 4.7 mg/1
TSS * 5. mg/1
Ammonia * 0.1 mg/1
Fecal 83/100 ml
* Effluent Sample
State Laboratory
8.9 mg/1
15 mg/1
<0.1 mg/1
57/100 ml
7. DATA HANDLING AND REPORTING: A comparison of laboratory
bench sheets and contract laboratory reports for the
months of March, May, and November, 1997, were made to
the monthly discharge monitoring reports (DMRs). No
problems were found in data transfer.

PAI RATING SCALE
Ratina General Description
A The facility has no problems with flow monitoring,
sampling, analyses or data calculating and reporting
procedures. The overall self -monitoring program and
the quality and reliability of the data reported to
state/federal agencies are excellent. The general
operation of the entire facility is also very good.
The facility has a few minor problems in one or more
areas of flow monitoring, sampling, analyses or data
calculating and reporting procedures. Examples include
infrequent calibration of flow monitoring equipment,
improper refrigeration of samples, slight discrepancies
in oven or incubator temperatures and not keeping
thorough records. The self -monitoring program is good
and the problems have no major impact on data
reliability. The overall operation of the facility is
very good.
The facility has a major or several minor problems with
flow monitoring, sampling, analyses or data calculating
and reporting procedures. Examples include
malfunctioning flow monitoring equipment, improper
sampling site, not dechlorinating fecal coliform samples,
unacceptable oxygen depletions and improper seed
correction factors in BOD analyses. The problems noted
at the facility cause the reliability of some of the data
to be questionable. The general operation of the overall
facility is good.
D There are major problems with flow monitoring, sampling
analyses or data calculating and reporting procedures.
Examples include estimating flow, collecting samples at
wrong locations, using improper glassware or equipment,
malfunctioning laboratory equipment, poor laboratory
techniques, or errors in data calculations. The problems
cause the reliability of the self -monitoring data to be
highly questionable. The overall operation of the
facility is fair.
Severe problems with flow monitoring, sampling, analyses
or data calculating and reporting procedures cause the
self -monitoring data to be unreliable. Examples include
no flow monitoring capabilities, wrong sampling
frequencics and procedures, using unacceptable analytical
techniques or fabrication of information. The self -
monitoring program and the general operation of the
facility is poor.

State of North Carolir
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary ss
Kerr T. Stevens, Director JAA
_/-'11 .t Jn 1 U V. May, '10,1999
PROSANT AIKATI,�
BASF CORPORATION
SAND HILL ROAD
ENKA, NC 27928
Dear Permiltee:
A�MA-
NCDENR
NORTH GAROLIN%'QER,ARTMENT OF
ENVIRONMENT ANR'NAn1R4:'Rr5OURCE5
M41,
Subject: NPDES Stormwaler Permit Renewal
BASF Corporation
Permit Number NCSOOO 179
Buncombe County
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000179. This permit expires
on November 30, 1999. In order to assure your continued coverage under your permit, you must apply to the
Division of Water Quality (DWQ) for renewal of your permit To make this renewal process easier, we are
informing you in advance that your permit will be expiring. Enclosed you will find an individual permit renewal
application form, supplemental information request, and Stormwaler Pollution Prevention Plan certification. Filing
the application form along with the requested supplimental information will constitute your application for renewal
of your permit. The application form must be completed and returned along with all requested information by June
14, 1999 in order to constitute a timely renewal filing.
Recent legislation modified the fee structure for DWQ permits. Renewal fees have been eliminated and annual fees
have been changed. The new annual fee for your permit is now $715.00 (you will be invoiced later this year for
your annual fee.) A copy of the new fee schedule is enclosed in this package.
Failure to request renewal by June 14, 1999 may result in a civil assessment of at least $250.00. Larger penalties
may be assessed depending on the delinquency of the request. Discharge of stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penalties of up to $10,000 per day.
If you have any questions regarding the permit renewal procedures please contact Aisha Lau of the Stormwater and
General Permits Unit at [phone], ext. 578.
Sincerely, -
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
cc: Central Files
Stormwater and General Permits Unit Files
- Asheville Regional Office
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50 % recycled/ 10%post-consumer paper

� n
�e NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
ASHEVILLE REGIONAL OFFICE
March 23, 1999
239
MR. RAY ACKERMAN
BASF CORP - FIBERS DIV
SAND HILL ROAD
ENKA, NO 28728
Dear Mr. Ackerman:
Your letter dated March 23, 1999 that describes
corrective actions for your analytical procedures has been
received and reviewed. The actions taken are acceptable for
your North Carolina Wastewater/Groundwater laboratory
certification. If a future inspection should reveal that the
violations cited in the inspection report were not corrected,
enforcement actions will be recommended.
Thank you again for your cooperation. Contact us at
(828)-251-6208 extension 285 if you have. questions.
Sincerely,
Gary Francies
Laboratory Section
cc: James W. Meyer
1 Asheville Regional Office'
I NTERCHANUE MUILPINO, 60 WOODFIN PLACE, AeX¢V ILLS, NC 28¢01-2414
P XON¢ 82E-291-8208 FA% E20.261-6G62
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER -EO% RECYCLED/10% POST-CONZUMER PAPER

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality A74,2
-
James B. M Hunt, Jr., Governor NCDENR
Wayne McDevitt, Secretary
Kerr T. Stevens, Director NORTH CIROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
3/31/99
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
PPy AIKAT
BASF CORPORATION
SAND HILL ROAD
ENKA NC 27828'NR
SUBJECT: NOTICE OF VIOLATION AND REVOCATION FOR NON PAYMENT gSf��E 19
PERMIT NUMBER NCS000179
BASF CORPORATION
BUNCOMBE COUNTY
Dear Permittee:
Payment of the required annual administering and compliance monitoring fee of $450.00 for this year has not
been received for the subject permit. This fee is required by Title 15 North Carolina Administrative Code 2H.0105, under
the authority of North Carolina General Statutes 143.215.3(a)(1), (is) and (lb). Because this fee was not fully paid within
30 days after being billed, this letter initiates action to revoke the subject permit, pursuant to 15 ncac 2H.0105(b) (2) (k)
(4), and G.S. 143-215.1 (b) (3).
Effective 60 days from receipt of this notice, subject permit is hereby revoked unless the required Annual
Administering and Compliance Monitoring Fee is received within that time. Discharges without a permit are subject to the
enforcement authority of the Division of Water Quality. Your payment should be sent to:
N.C. Department of Environment and Natural Resources
Division of Water Quality
Budget Office
P.O. Box 29535
Raleigh, NC 27626.0535
If you are dissatisfied with this decision, you have the right to request an administrative hearing within Thirty (30)
days following recipt of this notice, identifying the specific issues to be contended. This request must be in the form of a
written petition conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, Post Office Drawer 27447, Raleigh, North Carolina, 27611-7447. Unless such request for hearing is made or
payments received, revocation shall be final and binding. If you have any questions, please contact:
Mr. Forrest Westali, Asheville Water Quality Regional Supervisor, (704) 251-620B.
Sincerely,"
'^Kerr T. Stevens
cc: Supevisor, Water Quality Permits and Engineering Unit
Asheville Regional Office
County Health Department
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50/ recycled./ 10 % post -consumer paper

BASF Corp 10
G
Jl
a.--' W+AA 2a i994
�n
March 23, 1999 �Sy fiECT)OI$
Mr. James W. Meyer
Laboratory Section
Division of Environmental Management
North Carolina DEHNR
4405 Reedy Creek Road
.Raleigh, NO 27607-6445
Re: Laboratory Certification Inspection Response
Dear Mr. Meyer:
BASF
In response to your written request dated March 1, 1999, I am
Pleased to inform you that all the deviations identified during our
laboratory inspection have been corrected. Cited below are the
corrections made to the referenced deviations.
Sample Preservation
DEVIATION: The ammonia samples are not de -chlorinated and the fecal
coliform samples and the ammonia samples are not
verified to have been de -chlorinated.
Corrective Action:
TSS
Both ammonia and fecal coliform samples are
now de -chlorinated when we are chlorinating
the WWTP effluent. Documentation is being done
to reflect these preservation steps. We have
not needed to chlorinate our effluent in
several years and omitting these sample
Preservation steps was just an oversight by
our lab technician.
DEVIATION: The time in and out of the oven is not being documented.
Corrective Action: These times are now being recorded.
r.
Sand HIII Road, P.O. eox 669, Enka, North Carolina 28728-0669 [phone]

DEVIATION: The seed correction factor is too low.
Corrective Action: We have traditionally gotten our seed sample
from our lift station with the highest
sanitary load. This source is apparently not.
of sufficient bacterial strength to produce a
quality seed sample. We have ordered "Polyseed
BOD Seed Inoculum" from VWR Scientific with
which we will prepare our seed samples in the
future. This should eliminate this problem.
DEVIATION: The dilutions used to analyze the seed controls have
been too low since the last batch of seed has been
used.
Corrective Action: The correction action above should correct
this deviation.
DEVIATION: When all method quality control requirements are not
met, the reported data are not qualified.
Corrective Action: It is our intention to meet all quality
control requirements and if I am aware that we
have not done so, I will so qualify the data
reported on the DMR "
I trust thatthese actions satisfy .the correction of the deviations
cited. -
�arj
SSiiin
Ackerman "
Environmental Manager

Report: PE005
Performance Evaluation Report Page: 1
1n 2i�5- DMRQA Study Number 018 Date: 31DEC98
Permittee: NC0000299 BASF CORP ENKA PLANT
_________________________ _--__--------------------------_-----
Conc. V Reported True Acceptance Warning Performance
No. A Value Value* Limits Limits Evaluation
------------------------------------------------------------------------------
TRACE METALS IN MICROGRAMS PER LITER
015-ZINC
O1 618 631
563-
709
581-
690
Accept.
MISCELLANEOUS ANALYTES:
019-PH-UNITS
i
O1 8.59 8.60
8.31-
8.92
8.38-
8.84
Accept.
071-TOTAL CYANIDE(IN MG/L)
01 0.158 0.140
0.089-0.184
0.101-0.172
Accept.
072-NON-FILTERABLE RESIDUE(IN MG/L)
01 32.2 64.0
12.4-
80.7
20.9-
72.1
Accept.
097-TOTAL PHENOLICS(IN MG/L)
O1 0.066 0.0668
0.0261-0.108
0.0367-0.097
Accept.
098-TOTAL RESIDUAL CHLORINE(IN MG/L)
O1 1.04 0.930
-0.811-
1.32
0.878-
1.25
Accept.
NUTRIENTS IN MILLIGRAMS PER LITER:
031-AMMONIA-NITROGEN
O1 4.85 4.80
3.89-
5.84
4.13-
5.6
Accept.
032-NITRATE-NITROGEN
O1 11.7 12.0
10�.1-
13.9
10.6-
13.4
Accept.
034-KJELDAHL-NITROGEN
02 6.00 5.40
4.02-
6.79
4.35-
6.45
Accept.
035-TOTAL PHOSPHORUS
02 3.99 4.00
3.3-
4.68
3.47-
4.52
Accept.
DEMANDS IN MILLIGRAMS PER LITER:
038-5-DAY BOD
O1 40.8 37.6
17.7-
57.2
22.6-
52.2
Accept.
CERIODAPHNIA CHRONIC DATA AS % OF SAMPLE
766-SURVIVAL, NOEC - MHSF --
01
025.0 25
12.5-
50 NA
Accept.
767-REPROD.,
O1
IC25
- MHSF
025.8 17.6
0.31-
34.8 NA
Accept.
768-REPROD.,
O1
NOEC
- MHSF
012.5 12.5
6.25-
25 NA
Accept.
**********
END OF
DATA FOR
NC0000299
**********
NOTE: FOR
LIMITS
AND TRUE
VALUES, ASSUME
THREE SIGNIFICANT
DIGITS.
**********
END OF
REPORT FOR NC0000299
**********
* Based on gravimetric calculations, or a reference value06 cessary.
D.L. Means detection limit.
S 1999

GOVERNOR
wb�
NORTH CAROLIDEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
March 1, 1999
239
N
f� N� T� [
MR 2 1999
Mr. Ray Ackerman
BASF Corporation - Enka Plant
I ARORATORY SECTION
Sand Hill Road ASTIVILIE REGIONAL GFI10E__
Enka, NC 28728
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr. Ackerman:
Enclosed is a report for the inspection performed on February 18,
1999 by Mr. Gary W. Francies. Within thirty days, please supply this office
with a written item for item description of how these violations were
corrected. A response is not required comments or recommendations
unless specifically requested. If the violations cited in the enclosed report
are not corrected, enforcement actions will be recommended. For
certification maintenance, your laboratory must continue to carry out the
requirements set forth in 15A NCAC for 2H .0800.
Copies of the checklists completed during the inspection may be
requested from this office. Thank you for your cooperation during the
inspection. Please contact us at 919-733-3908, if you have questions or
need additional information.
Sincerely,
ii=ames. Mey!r�
Laboratory Section
Enclosure
cc: Marilyn O. Deaver
Gary W. Francies
Asheville Regional Office;
LA...ATORY 66CT10N
4905 R66DV CRE66 ROAO, RALEION, NORTH CAROLINA 29607.6446
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITI A0919MATIVEACTIOM EMP40YCR-30%RECYCLED/10% POST -CONSUMER PAPER

ON -SITE INSPECTION REPORT
LABORATORY NAME:
BASF Corp. -Enka Plant
ADDRESS:
Sand Hill Road
Enka, NC 28728
CERTIFICATE*
239
DATE OF INSPECTION:
2/18/99
TYPE OF INSPECTION:
Maintenance
EVALUATOR(S):
Gary Francies
LOCAL PERSON(S) CONTACTED: Ray Ackerman, Ross Peebles
INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of
environmental samples.
GENERAL COMMENTS:
The laboratory is spacious and well equipped. All equipment is well maintained. A new spectrophotometer has been
obtained since the last inspection. Records are well kept and most data appeared accurate. Some further quality control
procedures need to be implemented.
A Fecal Coliform sample was split with the following results:
BASF Laboratory
520/100 ml
Effluent samples were split with the following results:
State Laboratory
270/100 ml
BASF Laboratory State Laboratory
BOD, mg/I 17.9 26.2
TSS, mg/I 85 102
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS, and COMMENTS:
Sample Preservation
1.. VIOLATION: Sample preservation is not properly performed and documented. The ammonia samples are not
declorinated. Neither the ammonia nor fecal coliform samples are verified to have been dechlorinated.
REQUIREMENT: Samples received for analysis must be verified and documented to have been properly preserved.
Because a preservation method for one analytical method may interfere with another one, samples for multiple
determinations may need to be split and preserved separately. Sample container identification must be associated with the
analytical method(s) used. Each sample container must be checked upon receipt in the laboratory for the effectiveness of
any required pH adjustment solutions and the results documented. A two hour limit to chemically preserve samples by pH
adjustment is allowed, except for metals samples reported to the Groundwater Section which must be acidified at the time
of collection. The temperature of a temperature blank, or of a representative sample, if the second choice does not
compromise the integrity of the samples, from each cooler must be recorded upon receipt in the laboratory. Samples are
sometimes received above 6(C where transport time is less than two hours from the time of collection. For these samples,
temperature at the time of collection must be compared to temperature upon receipt to document a downward trend in
temperature. Samples containing chlorine must be dechlorinated at the time of sample collection and treated according to

ram,
rage 2
the requirements of the analysis to be performed. Upon receipt in the laboratory, samples must be checked and
documented to be free of chlorine. A variety of testing kits are considered to be adequate for most chlorine interference
checks and a maximum detection limit of 0.2 mg/L is allowed. When samples are received out of compliance, the lab must
inform the client and the State of NC in writing. Ref: 15A NCAC 2H .0805 (a) (1) and (7) (M) and (N).
COMMENTS: Chlorination of the effluent was begun in November 1998.
TSS
2. VIOLATION: The time samples are placed in the oven and the time samples are removed are not documented.
REQUIREMENT: If each sample is not redried and reweighed, the laboratory may verify that a specific drying time is
adequate to dry samples to constant weight. This verification may be performed annually by drying representative samples
for a determined time period and verifying that this time period is adequate with additional drying and weighing cycles. This
annual check must be documented. Additionally, the times samples are placed in the oven and the times samples are
removed from the oven must be recorded for each analysis thereafter. Ref: 15A NCAC 2H .0805 (a) (7)and (a) (7) (D).
BOD
3. VIOLATION: The seed correction factor is too low.
REQUIREMENT: Sufficient seed material must be used to yield a seed correction of 0.6 to 1.0 mg/I. Ref: Standard
Methods, 18th Edition - Method 5210 B. 4d 2.
COMMENTS: A new batch of seed was obtained in December 1998. Since then, only one set of samples has had an
acceptable correction factor.
4. VIOLATION: The dilutions used to analyze the seed controls have been too low since the last batch of seed has been
used. The final result of the seed correction factor is not always properly determined.
REQUIREMENT: Seed controls and all samples must have a DO usage of at least 2 mg/1 and a residual of at least 1 mg/I
in order to be acceptable for use. All dilutions that meet this criteria are averaged to obtain the final result. Ref: Standard
Methods, 18th Edition - Method 5210 B 5.
COMMENTS: In most cases, neither dilution depletes the required 2.0 mg/I. When one does, both dilutions are still used to
calculate the final seed correction factor. Only the acceptable dilution can be used in that case.
5. VIOLATION: When all method quality control requirements are not met, the reported data are not qualified.
REQUIREMENT: Whenever any of the method quality control requirements are not met, the data must be qualified on the
Discharge Monitoring Report(DMR). The qualifying statement should indicate that all QC requirements were not met. Ref:
15A NCAC 21-1.0805 (a) (7 and (a) (7) (D).
IV. PAPER TRAIL:
A review of data was conducted. This consisted of comparing laboratory bench sheets and contract lab reports to DMRs
submitted to this Division. Data were reviewed for the W NTP for these months: August, October, and November, 1998.
Data were reviewed for the four groundwater monitoring wells for 6113198. No errors were noted. It appears the facility is
doing a good job of accurately transcribing data.
V. CONCLUSION:
This laboratory is doing a good job overall. Correcting the above violations should help to produce quality data and meet
certification requirements.
Report prepared by: Gary Francies Date: 2124199